Skip to content
BOL Conferences
Thread Options
#1710494 - 06/14/12 05:47 PM Strange Scenario
jade1234 Offline
Member
Joined: Jul 2010
Posts: 97
Medford, Oregon
If a customer whose dollar volume of deposits and cash withdrawals is high, and the bank tries to obtain what the customer is retired from (customer is in his 50s) to justify the volume,refuses to give the Bank that information, is a report in order?

Return to Top
BSA/AML/CIP/OFAC Forum
#1710537 - 06/14/12 06:27 PM Re: Strange Scenario jade1234
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The instructions for the new SAR (like the old) mention the "elastic clause" in the SAR filing regulations that indicates a transaction is suspicious when "it is not the sort in which the particular customer would normally be expected to engage..." Also "suspicion concerning the source of funds" is one reason you might think the customer is laundering money. 33 (c)

Any number that is "high" is relative to some other number. Without all the numbers and all other information you might have on the customer, there's not enough to make a decision.

However, there is enough information here to make it clear that, if you do not file a SAR, you need to leave a paper trail that says why not.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z