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#1614954 - 10/12/11 07:50 PM My First Potential SAR?
Matt_B Offline
Diamond Poster
Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
What would you do or what follow-up questions would you ask to this scenario?

Customer opens an account in February of this year, obtains a credit card and vehicle loan soon after that have both been in good standing since. Information provided and verified for income has him making $10/hr at a 40 hr/week job, living with family.

I was contacted today by a branch manager wanting to share that a pattern of frequent cash deposits is making tellers suspicious of him. Never more than $2000 at a time, but he seems to average over $5,000 in cash deposits per month.

I was doing some investigating on transactions in and out and noticed that no checks are ever deposited but he has two checks come out every month paid to different property management companies (neither having any relation to the address he claims to live at).

To top it off, last month he sent an international wire to an individual in Canada of $10,000 which he brought cash in to pay for. On it's own, it didn't trigger any sort of suspicion, but it's got me curious. I have a feeling there are some shady dealings going on.

I'm trying to decide if I should continue to monitor at this point or file a report. Thoughts?
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#1614963 - 10/12/11 07:58 PM Re: My First Potential SAR? Matt_B
Tater Offline
Platinum Poster
Joined: Jan 2006
Posts: 642
Missouri
I would surely be monitoring this and continuing to dig around. If nothing else, it does not meet the "normal and customary" test for his stated line of business/work.

At this exact moment, I don't know if there's anything you can necessarily file on, but it's definitely worth monitoring, IMO.
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Opinions are my own and do not reflect any others

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#1614972 - 10/12/11 08:13 PM Re: My First Potential SAR? Tater
Bee Cee Offline
Member
Joined: Oct 2010
Posts: 97
Unless this activity can be explained, I would file a SAR and continue to monitor. From page 67 of the exam manual:

"Has no business or apparent lawful purpose or is not the type of transaction that the particular customer would normally be expected to engage in, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction."

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#1615001 - 10/12/11 08:53 PM Re: My First Potential SAR? Bee Cee
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
It has the potential for a SAR. I would inquire about the origin of the monthly cash deposits. Basically, where is it coming from? Could the employer be paying the customer in cash? This happens a lot here.

I would flat out ask him about the purpose of the checks and especially the cash deposit and outgoing wire. You have every right to inquire. If you don't like the answers, you could file a SAR. But again, I would continue the investigation prior to filing.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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