SAR Reportable Transaction

We had a customer come to one of our locations and withdrew cash in the amount of $20,000.00. A CTR was filed as required. In review of account activity this was the only large withdrawal on this individual over the past 4 months. He was president of a roofing company and is now retired. He has his social security check being deposited monthly. Keeps a large balance in account, around $70,000.

My question is should a SAR be filed on the $20,000 withdrawal even though a CTR was filed and no structuring was ocurring.

Thanks for your help.

You should only file a SAR if you think the transaction was suspicious. Determining that may require further investigation and/or a discussion with your customer.

In situations such as this, it is really hard to say whether you should file or not. Some banks file because the transaction is out of the norm or established pattern of the customer; we do not file solely based on this factor. Unless I had some background knowledge or facts to support my filing or a gut instinct that told me it was suspicious, I don't know that I would file in your case.

Also, one of the things I teach (and basically beat to death) in all of my BSA trainings, is that front line staff should ask questions. Using your scenario, if I were the teller the first thing I'd ask would be something along the lines of 'are you buying a new car?' or any open-ended question that would help me understand what the large withdrawal was for.

If we don't teach front line personnel to ask questions and actually communicate with our customers, that leaves personnel responsible for BSA monitoring and filing with a lot of questions such as yours. And needless to say, it makes our BSA lives quite difficult at times.

With large cash withdrawals, we like to approach it from a safety standpoint especially if the customer is elderly. Just with walking out the door with that much cash, we are concerned about their security, but there are also a lot scams going on and we want to make sure they are not a potential victim.

It makes it much easier for the branches to ask from this approach rather than just asking what they're doing with the cash.

I absolutely would not file a SUSPICIOUS ACTIVITY REPORT on a customer- obviously a known customer with an established relationship- just because he legally withdrew his own money. Just because he is retired does not mean that he is necessarily elderly.

I also would not file a SAR for a single large cash withdrawal. I've spoken with my auditor about this and I label those as "unusual but not suspicious at this time." Who are we to say that he didn't take that money and buy a new motorcycle so he can travel the world? Now, if it happened a second time and it couldn't be explained that's a different story....