Safe Deposit Box & BSA Reporting

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Question:

If a safe deposit box was drilled into by law enforcement officials and contained over $10,000 in cash and the law enforcement officials were given a cashier’s check in place of the cash, what BSA reporting requirements do we have?

Answer:

If you carefully get the correct information from the law enforcement official that will permit you to file a Phase I exemption on the officials' organization (as a government unit), you need only file the Designation of Exempt Person to avoid having to file a CTR. Given the discovery of the cash cache, you now would be wise to review any other relationships you have with the safe deposit customer to see if you discovery suspicious activity. Then weigh whether what you know warrants filing a SAR. It's important to see that the fact of the order allowing the drilling of the box doesn't by itself trigger a SAR. It's what you find after the drilling that triggers extra digging.

First published on BankersOnline.com 11/19/07