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In Response To:
Thread Starter: Anonymous
Title: Re: Suspicious Activity

I would like some help with this please.

A customer uses money that was allegedly stolen (illegally obtained) to use to start a legitimate business.

The allegedly illegally received money and the subsequent business were never used "as part of a plan to violate or evade any law or regulation or to avoid any transaction recordkeeping and reporting requirement under federal law."

Nor was the money used for anything else under BSA which would have/could have been violations and the transactions of the account holder and the account itself were not out of the ordinary from the type of activity the customer could have been expected to enage in...

However, after the fact it has been discovered that the intent of the series of transactions was to simply put distnace between the customer and their theft and confuse the location of the funds through tranfers and asset purchases and payoffs. Or in other words, the purpose of the allegedly stolen funds was to use it.

Again not in any violation of federal law other than alleged theft, more like gaming the system.

Is this an OTHER? or is this a Money Laundering filing? Or is this even a SAR worthy event at all?