We have determined that an employee of another bank in our area is bringing in large cash deposits in 100's and is then wiring the money overseas (the Phillipines); he is a customer of ours (strange). The bank is not a 314(b) sharer, so we have no safe harbor to contact them. Aside from filing a SAR, which we intend to do, is there any safe harbor provision under which I can contact that bank to make them aware without violating our customer's privacy? The customer is very tight-lipped about the wires, saying only that they are for "software equipment". There is NO indication that the software might be for his bank.

Is it permissible to contact them regarding their potential 314(b) registration? It wouldn't take long for them to get registered, then info regarding ML cases could be shared, right?

I would consider calling the bank's compliance officer and strongly suggesting to him that he sign up for sharing under 314b. Just tell him that he really does want to do this. I suspect he will follow your advice.

Make sure you document any 314b sharing specifically as a money laundering or terrorist financing investigation.

Great idea! I did just that and sent him an e-mail with the link to the registration page. I sure hope he hurries...

Do you and the other bank have the same regulator?

Unknown, but possible.

Find that out ... this may be a case to contact the regulator.

You should have just filed the SAR and let the people who receive the reports do the investigations. I know it's tempting to want to catch the bad guy, but your job is only the first step in catching them. That employee is definately up to something fishy!!