SAR

Customer deposits payroll checks into account. Perhaps 95% of the checks written out of this account are written payable to themself and either cashed or deposited at one other local bank. This is the majority of the entire account activity. Kiting? SAR worthy?

What relationship does the depositing of payroll checks have with the fact that they get cash out of the account.

There was kiting suspected previously, that activity stopped. Not sure if the current activity warrants ongoing monitoring or other action.

If I don't control or if I am not in collusion with someone that controls the accounts from which the deposits are coming from, how could this ever be considered a kite????

okay, i'm going to ask the obvious question - if you suspected kiting previously, why is the account still open? and now you have additional or ongoing monitoring on this account because of previous suspected activity. Is it worth maintaining the relationship?

His payroll checks or payroll checks payable to others?

We have a very similar situation. Guy owns business (that account is at another bank). The majority of checks into his account with us are payroll checks payable to others and signed over to him. Checks out are mostly payable to cash and deposited at the other bank.

I'm not comfortable with the activity and want to close the account.

In all likelihood, your and want2comply's customers are operating an unlicensed check cashing business... Ask them, then show them the gate.