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#2183213 - 06/26/18 07:47 PM POSSIBLE Sar
HereToLearn Offline
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Our customer ask for help counting money in her safety deposit box due to her arthritis. The bank employee of course filled out an incident report because of the cash in the box, but I am not sure if a SAR is necessary. There was $1500 in cash, this is an elderly lady that we have no reason to believe is doing anything illegal. Is it still necessary to file a SAR ?

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#2183218 - 06/26/18 07:54 PM Re: POSSIBLE Sar HereToLearn
rlcarey Offline
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Galveston, TX
For $1,500?? Also, you need to review your safe deposit box procedures at your bank. There is no way that should ever have happened. What are you going to do when her attorney shows up and says there was $20,000 in cash in her box and your employee must have stolen it? An employee should never accompany or be present when a box is opened unless totally in a dual control environment for official purposes. The only way this should have happened is if the customer removed the cash and replaced the box and brought it to the teller line.
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#2183223 - 06/26/18 08:18 PM Re: POSSIBLE Sar HereToLearn
John Burnett Offline
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Cape Cod
There's absolutely nothing I can conceive of that's suspicious about a customer with $1,500 cash in a safe deposit box.

Your staff member's response to the customer request should have been along the lines of suggesting that she can have a family member or friend assist her in counting the money if she needs the help. As Randy suggests, she could remove the cash and return the box to the vault and have it counted by a teller and then take it back, sign in again, and replace the case in the box, if she doesn't have anyone else to help her. It seems like overkill for a measly $1500, but it's protocol, and avoiding protocol can leave the bank exposed for a suit. No all little old ladies are as sweet as your grandmother.
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#2183225 - 06/26/18 08:24 PM Re: POSSIBLE Sar HereToLearn
P*Q Offline

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Somewhere
Agreed, an employee should NEVER enter the safe deposit box room with a customer.

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#2183256 - 06/27/18 03:05 AM Re: POSSIBLE Sar HereToLearn
JacF Offline

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PA
Please take to heart the great advice offered above about the best way to respond to similar requests and adjust (and enforce) your procedures accordingly.

Now to address your SAR question- I agree with the posters above that there is nothing inherently suspicious about an individual possessing $1500 cash, regardless of where it is stored. And an individual's decision to store their excess cash in a safe deposit box, in and of itself, shouldn't warrant escalation through the incident/SAR referral process. Even if this was a SAR-worthy scenario (and I would strongly contend that it isn't), you're well below the mandatory reporting threshold, and you don't have an instance of "activity" as defined in the regulation.

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#2183311 - 06/27/18 03:35 PM Re: POSSIBLE Sar John Burnett
Richard Insley Offline
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Toano, VA
Originally Posted By John Burnett
There's absolutely nothing I can conceive of ....
...currency is laced with white powder appearing to be cocaine?
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#2183335 - 06/27/18 05:07 PM Re: POSSIBLE Sar Richard Insley
edAudit Offline
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Originally Posted By Richard Insley
Originally Posted By John Burnett
There's absolutely nothing I can conceive of ....
...currency is laced with white powder appearing to be cocaine?


A note with it that claims that the money is the proceeds of an illegal transaction? <sarcasm font>
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#2183369 - 06/27/18 07:40 PM Re: POSSIBLE Sar HereToLearn
TryingtoComply Offline
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The West
Quote:
A note with it that claims that the money is the proceeds of an illegal transaction? <sarcasm font>


Note states: Sold painkillers to teenager down the street.

Still below the threshold and not reportable. However, an elder abuse report might be if this were true. wink
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