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#1744789 - 09/27/12 04:20 PM SAR or No SAR discussion of the day in CLE?
AMLMGR Offline
Junior Member
Joined: Jan 2010
Posts: 35
Customer comes in with $10,000 cash. Teller, for whatever reason, hands them a CTR brochure. Client changes their deposit to $9,500. Do you file a SAR for intent to avoid a CTR even though one wasn't warranted?

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#1744796 - 09/27/12 04:29 PM Re: SAR or No SAR discussion of the day in CLE? AMLMGR
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The fact that your customer is not a careful reader does not muddy his intent, he attempted to structure the transaction...
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#1744797 - 09/27/12 04:29 PM Re: SAR or No SAR discussion of the day in CLE? AMLMGR
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
I would.
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#1745026 - 09/27/12 08:59 PM Re: SAR or No SAR discussion of the day in CLE? AMLMGR
summergirl Offline
Member
Joined: Jul 2009
Posts: 52
Delaware
That would be a yes here as well.

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#1745766 - 10/02/12 02:31 PM Re: SAR or No SAR discussion of the day in CLE? AMLMGR
BC78a Offline
Gold Star
BC78a
Joined: May 2006
Posts: 311
New York
I agree - SAR
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#1745795 - 10/02/12 03:12 PM Re: SAR or No SAR discussion of the day in CLE? BC78a
Orrsislander Offline
100 Club
Orrsislander
Joined: Jan 2002
Posts: 112
It is not reportable if it was $10,000 even. No CTR and no SAR is necessary in my opinion.

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#1745819 - 10/02/12 03:41 PM Re: SAR or No SAR discussion of the day in CLE? AMLMGR
BSA all the way Offline
Member
BSA all the way
Joined: Jan 2011
Posts: 74
No CTR but he structured for sure.
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