Customer withdrew $9900. one day and came back the next for another $9900. (both cash withdrawals). Came back a couple days later for $8500. (cash) and the manager finally questioned the customer and he said he was giving it to his daughter for a house. It appears he stayed below the reporting threshold which to me seems suspicious, however, he is a long time customer that offered up why he was withdrawing cash to begin with. I know this should be cut and dry but, I'm still fairly new to the BSA position and it doesn't seem that anything is cut and dry..

So if he was giving the money to his daughter to buy a house, why not just write her a check for the full amount? Or write a check to the contractor, seller, real estate company or title company? Sorry, to me it sounds like he didn't want a paper trail for some reason and that makes me suspicious.

Regardless of why he gave cash versus a check, it looks like structuring and I would report it. Structuring is a crime under the BSA, even if it was for a legitimate purpose. I would file. You may also want to provide the customer with the structuring brochure from FinCEN.

Long time customer or not, explanation provided or not, this is structuring and is worthy of a SAR. I don't see how you could document and defend any other decision.

SAR.

SAR.
The reason for the withdrawal is not relevant.
The manner of withdrawal is - it was structured.

I agree with the previous posters. File the SAR.

Thank you everyone! It has been filed.