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Unusual Withdrawals From a Non-suspicious Customer: Do we file an SAR?

We have a problem at our bank that we aren't sure how to handle. An elderly, long time deposit customer of our bank has started to withdraw her funds in large amounts. She has been instructed by her lawyer to do this, to prevent her husband's nursing home from taking all their savings. She has withdrawn $9,990 per day for three days in a row. Regulations say a CTR should be filed for mutiple transactions ON A SINGLE DAY. Memos I have read say we should file a SAR for the multiple withdrawals. My problem: we know the customer. We know she is not a drug dealer, criminal or terrorist. She is withdrawing her own money. I feel that our filing a SAR would be a waste of the FBI's time, when they are looking for money launderers and terrorists. Should we file one anyway, to cover our butts? Or can we just note to our files our reasons for not filing.

Answer by: Barry Thompson

Always file the SAR but contact your local FBI Office as one of their staff coordinates the SAR reports. Let that person know that no action is needed and why.

When filing a report always describe the incident fully! One SAR filed with the FBI stated "Burned Money" with no further description. This type of filing causes problems as a follow-up would definitely be needed by the Bureau and they won't be happy if it requires no action.

When filing SARS in my days as a Security Officer, I would state if further action wasn't necessary. It would still be up to the Government if they want to pursue it.


Answer by: Dana Turner


Has a bank employee counseled this customer about scams that target the elderly? Has anyone met with her attorney to discuss this strategy? Does she have any relatives who could extort money from her? Could a nursing home employee be extorting money from her?

It's unreasonable to believe her "story". Nursing homes bill their clients for services and expenses -- they don't go after their clients' life savings.

While banks may not have a legal obligation to inquire into their customers' withdrawal activities (other than Barry's comments), I believe that we have a moral obligation to investigate customers' activities that are suspicious, strange, unusual, bizarre -- or ones that are out of character for the customer or the account.

As a former police detective who's investigated a lot of similar circumstances, you've made the hair on the back of my neck stand up. I suggest that you have the security officer interview the customer -- immediately.

First published on 11/5/01

First published on 11/05/2001

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