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#546063 - 05/10/06 06:45 PM Sar right away or monitor for more?HELP!
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Cust. came in to dep. $1500.to his account. Acct. opened 15+ yrs. ago. At time of deposit cust. had/didn't offer ID. Also asked for limits for future purchases of official checks - to avoid our manual recordkeeping of cash usage > $3,000. Cust. got cold feet, took money ($4500.00) and left bank. No further trans. in account (been a month+)No big trans. in account for years. In such cases, do you have a policy of doing a SAR right away, as soon as a customer asks about recordkeeping policies then cancels trans. or do you monitor for another such incidence? I am on the fence about this as this is not a repeat, guy is retired, etc. and the amount is not significant.

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#546064 - 05/10/06 08:20 PM Re: Sar right away or monitor for more?HELP!
New to Compliance Offline
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Joined: Apr 2006
Posts: 59
Tucson, AZ
I would have filled out the SAR right away. He was fishing for information to avoid reports. When in doubt, fill out. I would rather report something that may not be anything rather than not report and it turns out to be something.
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#546065 - 05/10/06 08:42 PM Re: Sar right away or monitor for more?HELP!
MyKidsMom Offline
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Joined: May 2004
Posts: 641
TEXAS
But I believe the $'s involved here is below the reporting limits, isn't it?

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#546066 - 05/12/06 02:23 PM Re: Sar right away or monitor for more?HELP!
palmertown Offline
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Joined: Nov 2004
Posts: 65
Pennsylvania
I would have filed the SAR right away also. I don't believe the dollar amount comes into play because you would be reporting on the fact that he questioned your filing limits and then did not complete the deposit.

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#546067 - 05/12/06 07:25 PM Re: Sar right away or monitor for more?HELP!
Dip Offline
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Dip
Joined: Mar 2005
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San Diego, CA
file the SAR and let the government decide if it's suspicious
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#546068 - 05/12/06 07:49 PM Re: Sar right away or monitor for more?HELP!
Data Offline
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Data
Joined: Oct 2002
Posts: 226
Houston
Sorry, I do not agree with defensive filings. Known retired customer doing something dumb. Call the customer up and ask him what he was doing. Don't clog the pipe.
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#546069 - 05/13/06 04:04 PM Re: Sar right away or monitor for more?HELP!
Princess Romeo Offline

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Where the heart is
I agree with Data. We do not need SAR's to become the 21st century version of "Big Brother" and reportng every furtive glance or oddly dressed person.
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Regulations are a poor substitute for ethics.
Just sayin'

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#546070 - 05/13/06 04:13 PM Re: Sar right away or monitor for more?HELP!
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Quote:

Also asked for limits for future purchases of official checks - to avoid our manual recordkeeping of cash usage > $3,000. Cust. got cold feet, took money ($4500.00) and left bank.




My concern - this question and subsequent change in transaction (no transaction) are indicative of evading reporting requirements of Bank Secrecy Act, which is reportable, whether we think it is stupid or not.
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#546071 - 05/13/06 04:25 PM Re: Sar right away or monitor for more?HELP!
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
But $4,500 is under the SAR reporting threshold. IMHO, the account should be monitored to see if the customer starts conducting transactions that would be indicitive of structuring.

He may have received some bad info along the lines of "If the bank records your transaction, they file it with the IRS and that could trigger an audit." He may also be afraid of identity theft.

There is a reason the SAR reporting threshold was set at $5,000, and when the industry starts to voluntarily lower that threshold, we could really set ourselves up for program failure later on.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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