Employee SAR

Posted By: DerrickAuditor

Employee SAR - 10/08/09 10:48 PM

Looking for advice on how to handle a teller who has a major gambling addiction (clearly evidenced in the teller’s personal DDA - writes dozens of checks to the gambling establishment weekly). The teller also makes a lot of cash deposits. The gambling and cash deposits add up to three times the teller's take home pay (over $4,000 per month) - yet the account's avg balance is only $115 YTD.

We performed a surprise cash count on all vaults, drawers, and the ATM at the branch - only a $.59 outage. We reviewed all cash out transactions for three months and any activity on inactive or dormant accounts and found nothing. Audit and HR has met with the teller a few times and she swears all the cash comes from gambling winnings, but considering the odds of winning are less than 1% (per a gaming website) and she seems to make deposits that almost exactly match her gambling spending - it doesn't add up. We pulled another credit report - nothing unusual.

We filed a SAR - any other advice? We are also concerned with how the examiners will feel about us filing a SAR on an employee yet continue to let the employee work here – they have been critical of that in the past, yet HR doesn’t think we have enough to terminate employement. Thank you.
Posted By: rlcarey

Re: Employee SAR - 10/09/09 12:55 AM

"We filed a SAR - any other advice?"

Why did you file a SAR? Is she gambling in illegal establishments. Last I checked, if the casino is a legal casino, gambling is not criminal activity, even at the level of a gambling addict, unless there is suspected additional illegal activity.

The odds of winning are not 1% - so don't believe anything you read on the Internet. Depending on the game, the house odds may be as low as a couple of percent of every wager.

If you suspect she is a security or embezzlement risk, just fire her.
Posted By: Kathleen O. Blanchard

Re: Employee SAR - 10/09/09 03:28 AM

Other than illegal gambling, the close #s on checks out and cash in makes me wonder if this is money laundering. It is certainly unusual activity that is hard to explain.

I would worry about a teller, with access to cash, having a gambling addiction and would want to limit my risk by ending the relationship. Why continue and have to monitor the account and the branch?
Posted By: BrendaC

Re: Employee SAR - 10/09/09 01:51 PM

Have you considered moving this individual into an area where she does not have access to cash or unmonitored account entries?
Posted By: DerrickAuditor

Re: Employee SAR - 10/09/09 06:48 PM

To better explain, gambling is on pull tabs at a local charity club, not casino gambling where, yes, the odds can be better.

Out of 3,900 cards in a set sold for $1 each, only 16 cards pay between $50 and $250. The 1% came from the odds of winning at least $10 (39 of 3900 cards). We filed a SAR, not because of gambling, but because of the $4,000 in cash deposits each month doesn't seem reasonable based on the explanation given (winning pull tab games).

Also, this has been going on for six months. I'd say a lucky month here and there seems reasonable - but every month coming out almost exactly even? Doubtful. Thanks.
Posted By: BrendaC

Re: Employee SAR - 10/09/09 06:54 PM

I hope she doesn't read these threads.
Posted By: Kathleen O. Blanchard

Re: Employee SAR - 10/09/09 07:22 PM

I agree with you...it is the even dollars that seems very unusual, making me think of laundering funds for someone (or for herself).