Thread Starter: Sammy Sarosaurus
Title: Re: SAR for cash out, when source of funds is legit?
|
Customer's business involves consulting work. She gets paid by a lot of clients, and they all pay by check. Many of these are large, well-known local companies, and they always clear.
She deposits the checks here, 1 or 2 per week. The following week, she gets out a nearly-equal amount in cash. For instance if she deposits an $8,500 check this week, she'll be back next week to withdraw at least $8,000 in cash. Next week if she deposits $6,250 by check, she'll come back about a week later and withdraw $6,000 in cash. If she deposits two checks for $3,325 each, she'll come back a week later and take out $6,000 or $6,500. This totals well over $200,000 per year in cash outs. There are never any CTRs (well, maybe 1 or 2 per year) because the weekly deposits (which are the basis for her amounts to get in cash) are always below $10,000. There does not appear to be any attempt to hold the checks to avoid CTRs (based on the dates the checks say they were issued). There does not appear to be any attempt to split large payments up into multiple checks (if someone owes her $12,217, the check is for $12,217, and her next cash out will be $12,000).
Do you see a SAR? What type of activity? I do not see structuring in this. It's just a "Hmm, that's a lot of cash" type of SAR and there's no checkbox for that express reason. Having doubts about filing a "no apparent economic, business, or lawful purpose" SAR (which, by the way, is under the heading of "money laundering" because how can this be laundered money if we know the source is legit?)
|
|
|
|
