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Asking What Cash is Being Used For (Over $5,000)

Answered by: 
David A. Dickinson
Ken Golliher

Question: 
Our BSA officer insists when a customer deposits or withdrawals over $5,000 in cash, we have to ask what the cash is being used for. Is there regulation to support this? I understand CDD, but isn't this taking it too far? Is it our job to be nosey?
Answer: 

by David Dickinson:

Your BSA Officer is thinking about the potential to file a SAR. Since SAR thresholds are set at $5,000, if someone deposits/withdraws that much or more in cash, you need to have a reasonable explanation. If you don't have a reasonable explanation, you may need to file a SAR. So, if the customer doesn't give you an explanation and you don't ask, how do you know if you should file a SAR?

Technically, it is your job to be nosey.

Answer: 

by Ken Golliher:

Your BSA Officer is thinking about the potential to file a SAR. Since SAR thresholds are set at $5,000, if someone deposits/withdraws that much or more in cash, you need to have a reasonable explanation. If you don't have a reasonable explanation, you may need to file a SAR. So, if the customer doesn't give you an explanation and you don't ask, how do you know if you should file a SAR?

Technically, it is your job to be nosey.

First published on 03/04/2018

Filed under: 
Compliance
Filed under compliance as: 
BSA

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