Had a call about a CTR yesterday, a new account being opened and the couple had ~$39,000 in cash.

They told our new account person that their personal banker at XYZ Bank told them to take out small amounts of cash at a time, so this cash was piling up at their home over the last six months.

I don't know why they would be told to do that when they didn't attempt to structure their deposits, so I don't feel they're paticularly shady, but would you consider a sar for the unknown individual at the bank that it seems advised them to structure their withdrawals? It's kind of fuzzy on details and there's really no facts to back up the statement so I'm on the fence about it but will be watching the account anyway.

If they told you they robbed a bank to get the money would you file a SAR? (Hopefully you said "yes"). They've told you a crime (structuring) was involved in obtaining the funds. We don't get to choose which crimes we report.

I would absolutely file!

They weren't coached very well if they are trying to put it all back into another bank at once. File if you want, you are always more than free to file on anything you want to.

Someone told your CSR a story. Your bank is involved only to the extent your employee heard the story in your lobby vs. the check out lane. It's doubtful you have a subject and you have no supporting documentation.

Moreover, the transactions were not "...conducted or attempted by, at, or through..." your bank. If you file, it's voluntary. I would save a stamp.

Thank your employee for relating the anecdote... Hmmm, the story could be a nice red herring crafted to distract you. Watch the new account.

Thanks for the feedback. It makes sense to not report, and also to monitor the account.

I would file - only because my LE people would love the extra info. You never know what full picture they see.

I'm with Ken- neither the structuring nor the coaching were done at your bank. There's nothing to file.

To Greg's point about "a crime (structuring) was involved in obtaining the funds"- the difference between structuring and robbery is that the structurer still lawfully owns the currency in their possession- the robber does not.

It's a toss-up. One the one hand, if XYZ Bank is coaching people on how to structure, that is something that might be useful for FinCEN or their regulatory agency.

On the other hand, all you have is heresay which does not seem to justify the amount of work that goes in to filing a SAR.

I'll agree with Ken, Randy and Agent P. Watch the account. If you do find you need to file a SAR on the account, then the comment can be included in the narrative.