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#2097350 - 09/07/16 09:58 PM Cash in SDB
BankLady011 Offline
Junior Member
Joined: Aug 2016
Posts: 25
Way back when I was opening accounts and allowing customers access to their SDB I was always told cash was an item that should not be allowed in the box. We were instructed to notify the BSA Officer at the time if we became aware of a customer that was doing so. Now a days that BSA Officer is me (yay) and in training the staff I have passed along the message. I am being questioned as to why that is and am coming up with not a whole lot. Is this a law or just best practice determined by the bank? I am in Texas if that makes any difference.

Thanks!

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BSA/AML/CIP/OFAC Forum
#2097369 - 09/08/16 02:21 AM Re: Cash in SDB BankLady011
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Safe deposit contracts oftentimes prohibit storing currency in the box. Obviously, the safe deposit custodian would have absolutely no idea if the renter violated the restriction unless there was a "mysterious disappearance" and the renter alleged that cash stored in the box was now missing. (Easy to allege and hard to disprove.) The contractual provision gave the custodian a "pat" reason to turn down the claim: i.e. Maybe there was cash your box, maybe there wasn't. Either way, we told you not to store cash there so we have liability.

The language and the rationale predates the Bank Secrecy Act by a hundred years or more.

Obviously, some customers keep cash in their safe deposit box and they are goofy enough to make bank personnel aware of it. The FFIEC BSA/AML Examination manual contains 1 or 2 examples where the activity might be suspicious.

There are more important things to drill into your personnel.
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#2097376 - 09/08/16 11:29 AM Re: Cash in SDB BankLady011
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
I think I would focus more on training scenarios in which large over the counter cash transactions occurred before or after access to a safe deposit box might indicate structuring. Bad guys want their cash to be safe, but they don't want us to file CTRs so they store over $10k in cash in the box to keep it safe, then structure the deposits. Or they structure withdrawals and store the cash in the box until it's needed. I would make sure that they know to contact the BSA/AML officer if those or similar situations arise. As Ken said, we should not know what is in the box and instructing employees that cash can't go in the box because that's what we've always been told is missing the point as it relates to BSA/AML.
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Knowledge is knowing what to say. Wisdom is knowing when to say it.

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#2097406 - 09/08/16 01:36 PM Re: Cash in SDB BankLady011
Sunpokey Offline
Junior Member
Joined: Nov 2015
Posts: 28
We had a teller inform us of a large cash deposit that was made after the customer exited the safe box room. A CTR was trigged but in our write up we couldn't honestly say if the cash was on the customer when he went in the safe box room or was taken out of his safe box since we do not follow them in there or have camera's in the safe box room. Obviously if there had been suspicious activity after the deposit we would have had more questions, but since there's no law saying you cant have cash and couldn't determine if it was really from his safe box, we didn't waste any more time on the matter.

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