I know that attorneys are responsible for keeping track of transactions out of their IOLTA accounts and the way to do that is by writing checks. We have one attorney who will go the branch and instead withdraw from the IOLTA account and issue multiple Cashier's Checks to one of his clients. The client then goes to the branch and cashes them at different times. The individual amounts are large enough to warrant a CTR and they are filed regularly but I'm wondering why he would disburse the funds in this way to this one client? An internet search shows his client has been charged with stealing money from elderly associates.
Maybe I'm looking into this too much but I find it odd that he's conducting the transactions like this for one particular client and since I'm not an expert in IOLTA accounts I don't know if this is a way to hide or layer the disbursements to a individual who's currently charged with stealing from others.

You're right, that's incredibly odd. Is there any way you can match the money going out to funds coming in; e.g. the client received $30,000 in disbursements in a 30 day period, are there funds from a single source coming into the account from another person or entity in the same time frame that approximate that amount?

In other words, could the attorney be acting as the paymaster for an identifiable third party?

P.S. It could be more than one entity or individual making the deposits; i.e. the account could be being used as a "funnel" to aggregate payments from several sources. Look for recurring checks from one or more sources.

It's a single practice so I should be able to piece some things together. Guess I know what's on my agenda for tomorrow!
Thanks for confirming I wasn't totally off base!

I did some reasearch and I'm getting that 'don't like this' feeling.
The law practice specializes in tax law. The money that is being w/d and issued to his client in multiple cashier's checks is coming in via wire from a auction house. It's happened more than once this year.

My stock response is "Ask the customer what he's doing." I'm reluctant to do that here because I'm pretty sure that the attorney is doing something of which Hoyle would not approve.

As indicated by the fact that they are ineligible for exemption, auctions can very readily accommodate money laundering.

If the auction was selling something for the client, he could pay the client directly. Instead, he's paying the lawyer. If the lawyer was just a straw man for the client, he could write the client a check. Yet, by buying the official checks, the lawyer may believe he is eliminating a paper trail to the client.

Learn a bit more about the auction house and the attorney's practice and put it in your stack for SAR consideration.

Wish I could help you investigate and write!

Story about how attorneys sometimes get involved in their clients' business activities.

That was my plan exactly.
Thanks for your advice, this is an interesting one!

Whoa, something stinks to high heaven here as far as I am concerned. I believe I would fall back on the old "We reserve the right to not do business" clause.