Just Doing Their Job

There were two little "Mom and Pop" stores in the Midwest that had accounts in the local bank. The tellers, having been trained in the Bank Secrecy Act, filed Currency Transaction Forms (CTR- Form 4789) whenever they had a deposit or withdrawal in cash over $10,000, just as they were supposed to do. So it happened as a matter of routine that when the owners of these two accounts started to withdraw large amounts in cash on a daily basis of over $10,000, the tellers started filing CTRs.

There were so many filings that it came to the attention of Internal Revenue Service Criminal Investigation Division (IRS-CID) where it triggered an investigation.

A study and analysis of the subpoenaed bank records showed that in one year, there were over 200 CTRs filed reflecting over $8 million in currency transactions.

The records also showed that on some days the businesses made multiple deposits to the bank with each deposit having 200 to 300 checks.

Copies of the deposited checks revealed that in one year alone over 350 individuals and corporations cashed checks in amounts exceeding $5,000. Some of the checks cashed by the "Mom and Pop" stores ranged from $40,000 to $76,000 each!

To date there are 200 cases now pending. Forty-four (44) have been closed with tax and penalties of over $l.3 million.

All because the tellers were doing their job as they should.

Copyright © 1992 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 3, No. 4, 8/92