Thread Starter: Elwood P. Dowd
Title: Re: Cash stored in a safe deposit box - SAR?
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Appendix F in the BSA/AML Examination Manual lists a number of transactions involving safe deposit boxes as "red flags," but finding cash in a safe deposit box is not one of them. Agreeing with your observation that opinions will vary, there is no dollar figure at which I would automatically file a SAR on cash found in a safe deposit box.
It would depend on facts and circumstances; e.g. if it was $100K and the renter died of:
* old age at 85, not having been in the box a year or
* a gsw to the chest after a street corner shoot out, having visited the box 4 times a week during the last 3 months
I would make different decisions on the SAR, but my CTRs would be strikingly similar.
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