File a SAR?

Posted By: Likes to Comply

File a SAR? - 09/20/11 09:36 PM

Customer received $55,000 from attorney for estate settlement in April and deposited it into personal DDA. A month later the customer transfered $20,000 from personal savings to personal DDA. Thereafter, customer went his Loan Officer (customer said for privacy reasons) at Main Office to withdraw $100,000 from personal DDA. Then customer goes to our other branch in another town where he holds a safe deposit box for his company, where he puts a large envelope. 3 months later he enters the box again, removes the envelope and proceeds to the teller to make deposit. Money is all large bills , with the straps stamped with the name of the Main Office and date of the withdrawal. He deposits $85,000 cash. Later a check clears from his account for $85,000 with memo section stating "Comm Prop Settlement". Seems suspicious, but essentially he moved money from his account to safe deposit box then back to his account. But "Comm Prop Settlement" suggests a divorce. He was maybe hiding the money? What is your opinion? Is this SAR worthy?
Posted By: Kathleen O. Blanchard

Re: File a SAR? - 09/20/11 09:38 PM

Why does comm prop settlement suggest a divorce? Perhaps it is funds for a settlement to purchase a commercial property? Of course those of us reading this do not know to whom the check was payable.

Posted By: ACBbank

Re: File a SAR? - 09/20/11 09:53 PM

There's a lot of speculation at the moment. I would contact the customer and inquire about the nature of the transactions. If they refuse to provide any reasonable answers, I would then move forward with an SAR.
Posted By: edAudit

Re: File a SAR? - 09/21/11 12:36 PM

It is not against the law to keep money in a SD box.

FWIW it usually takes longer than 3 months for a divorce settlement and the 55 from the atty may or may not be a part of the settlement, so out of the 100,000 you know where at least 75,000 came from and if you think that "Comm Prop Settlement" suggests that he paid for his divorce I do not know what is suspicious.(other than possibly the 25,000 cash.

Just my opinion
Posted By: Likes to Comply

Re: File a SAR? - 09/21/11 01:50 PM

Thanks for the help!