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#1264228 - 10/08/09 10:48 PM Employee SAR
DerrickAuditor Offline
Member
Joined: Mar 2008
Posts: 91
USA
Looking for advice on how to handle a teller who has a major gambling addiction (clearly evidenced in the teller’s personal DDA - writes dozens of checks to the gambling establishment weekly). The teller also makes a lot of cash deposits. The gambling and cash deposits add up to three times the teller's take home pay (over $4,000 per month) - yet the account's avg balance is only $115 YTD.

We performed a surprise cash count on all vaults, drawers, and the ATM at the branch - only a $.59 outage. We reviewed all cash out transactions for three months and any activity on inactive or dormant accounts and found nothing. Audit and HR has met with the teller a few times and she swears all the cash comes from gambling winnings, but considering the odds of winning are less than 1% (per a gaming website) and she seems to make deposits that almost exactly match her gambling spending - it doesn't add up. We pulled another credit report - nothing unusual.

We filed a SAR - any other advice? We are also concerned with how the examiners will feel about us filing a SAR on an employee yet continue to let the employee work here – they have been critical of that in the past, yet HR doesn’t think we have enough to terminate employement. Thank you.
Last edited by DerrickAuditor; 10/08/09 10:52 PM.
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Human Resources
#1264245 - 10/09/09 12:55 AM Re: Employee SAR DerrickAuditor
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
"We filed a SAR - any other advice?"

Why did you file a SAR? Is she gambling in illegal establishments. Last I checked, if the casino is a legal casino, gambling is not criminal activity, even at the level of a gambling addict, unless there is suspected additional illegal activity.

The odds of winning are not 1% - so don't believe anything you read on the Internet. Depending on the game, the house odds may be as low as a couple of percent of every wager.

If you suspect she is a security or embezzlement risk, just fire her.
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#1264266 - 10/09/09 03:28 AM Re: Employee SAR rlcarey
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Other than illegal gambling, the close #s on checks out and cash in makes me wonder if this is money laundering. It is certainly unusual activity that is hard to explain.

I would worry about a teller, with access to cash, having a gambling addiction and would want to limit my risk by ending the relationship. Why continue and have to monitor the account and the branch?
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Kathleen O. Blanchard, CRCM "Kaybee"
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#1264417 - 10/09/09 01:51 PM Re: Employee SAR DerrickAuditor
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Have you considered moving this individual into an area where she does not have access to cash or unmonitored account entries?
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#1264838 - 10/09/09 06:48 PM Re: Employee SAR rlcarey
DerrickAuditor Offline
Member
Joined: Mar 2008
Posts: 91
USA
To better explain, gambling is on pull tabs at a local charity club, not casino gambling where, yes, the odds can be better.

Out of 3,900 cards in a set sold for $1 each, only 16 cards pay between $50 and $250. The 1% came from the odds of winning at least $10 (39 of 3900 cards). We filed a SAR, not because of gambling, but because of the $4,000 in cash deposits each month doesn't seem reasonable based on the explanation given (winning pull tab games).

Also, this has been going on for six months. I'd say a lucky month here and there seems reasonable - but every month coming out almost exactly even? Doubtful. Thanks.
Last edited by DerrickAuditor; 10/09/09 06:58 PM.
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#1264845 - 10/09/09 06:54 PM Re: Employee SAR DerrickAuditor
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I hope she doesn't read these threads.
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#1264874 - 10/09/09 07:22 PM Re: Employee SAR DerrickAuditor
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I agree with you...it is the even dollars that seems very unusual, making me think of laundering funds for someone (or for herself).
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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