I'm struggling with whether or not to file a SAR. My gut says yes, but others have a difference of opinion.

We have a customer who opened an account a few years ago, was listed as a student at the time, and is in her early 20s. This person has deposits cash every two weeks or so. Sometimes every three weeks, sometimes a few days apart. It's ranges from 1k-3k each time. I see regular payments coming out of the account each month: mortgage, utilities, etc. This has been her pattern since day one.

While it is part of this person's regular activity, I would say to file a SAR for suspicious source of funds. Just because this is the pattern, doesn't mean there's not something going on.

We have to throw that one back to - has anyone spoken with the customer to ask for the source of cash?

A senior teller or branch/operations manager should have a discussion with the customer.

There are many reasons why someone would be depositing that amount of cash - some reasons are legit, others are not.

Right now, you don't have enough to file an "intelligent" SAR. Someone at the bank needs to talk to the customer. Even if the customer refuses to answer any questions, at least you have more to go on besides "Well that seems odd...."

Did anyone contact the customer to ask? or up date her profile?

The entire Class of 2012 was comprised of Students a few years back.

Does the customer either have direct deposit and/or deposit payroll checks into the account? The source of the funds could legitimately be from payroll checks cashed at another institution that the check was drawn on and then deposited as cash to be readily available. The timing of the deposits could also depend on a number of factors such as work schedule, personal schedule, personally anything in the world would keep me away from going to the bank!

I'm going to join the chorus of contacting the customer. Sometimes there are legitimate reasons for why people make cash deposits.

Maybe she's a bartender, maybe she's a waitress, maybe she's something else...

If you ask, she could tell you if it's one of the first two and you could verify it.

The only source of funding for this account is cash.

I agree with everyone's comments. Thanks for the input. I had originally asked the question to the analyst as to whether the branch had any more information or could get more information and the answer was that she goes to a few different branches in the area. I've asked him to contact the branch of account and have them reach out to the customer.

I agree there's lot of reasons why someone would use cash only. Cash isn't illegal, but I think in this day and age of technology we, or at least I, tend to raise an eyebrow when someone deals in cash.

Why arent tellers asking questions and making conversation with customers? KNOW YOUR CUSTOMER

She comes in every 3 weeks and makes deposits in 1-3k in cash and teller never greets her by name, never asks how her week has been? hows the job? where do you work? you busy during the holiday season? do you get paid in cash? does your employer offer direct deposit?
obviously not all at once, but have a conversation. customer service and doing your job.

we had branches have contests to see who could remember and use customers names when greeting them at teller window. Tellers liked it, everyone was more sociable, customers and tellers alike, when those branches were contacted for info about SARs, they almost always knew the background info or story that was needed.

Othom,

All good comments, however the OP stated: "she goes to a few different branches in the area", so it might not be that easy unless you can flag the account in some manner on the teller system to "ask questions next time you see this customer". Some banks have such an alert system.

Thank you, rlcarey. That's exactly it. I originally made the suggestion of talking to the customer when they come in next time. That's when I found out they go to several different branches so they might not see the same teller very often. And this is a new core system (and new bank) for me so I'm not sure if we can flag the account. I have to check into that. The tellers here are actually really great about getting to know their customers.

My plan is to file in the event the branch can't get in touch with the customer (we're running up against a deadline). We can always decide not to re-file in 90 days if we get the necessary information and decide it's not suspicious.

Call your customer. Have an officer tell her that you are updating records and could she stop by and see you next time she is at the bank.

I have been a few decades in realizing just how far banks will go to avoid asking their customers some very obvious questions either in person or on the phone. Beyond that, when you suggest a site visit is appropriate, their eyes go wide in disbelief.

The customer knows the answers to the questions. If they tell the bank employee it's none of their business, they may very well be right, but at least the bank's speculation is somewhat less blind and there's one more pea added to the "suspicious" side of the scales.