Sorry to post this as anonymous, but it's a sensitive issue. We have a customer who has requested to withdraw in excess of $100,000 in cash. Although he had initial concerns about the CTR filing, he does not want a Treasurer's check, and has asked for the cash (in $100 bills)on a specific day. We have several concerns: is the customer a potential scam victim, is he involved in illegal activity, what's the physical risk in letting him walk out the door with so much cash? We are filing a SAR based on his initial questions re: the CTR. Should we also notify the police that we have safety concerns for an individual withdrawing a large sum of cash? How much info could we give them about the transaction (e.g. name, and vague dollar amount) without running afoul of RFPA and GLBA? Thanks.

It's not unlawful (yet) to hold cash. So file your CTR. Unless the customer has a pattern of large cash withdrawals or transactions, it's hard to say one instance is suspicious enough to warrant a SAR. As for his safety, if he appears to be of sound and independent mind, I probably wouldn't call law enforcement. I would report it if I thought he was being scammed, however.

I agree with Ken. It is a single instance and the transaction will be documented through the CTR channels, so a SAR would probably be of little value at this point. That being said, I think it's prudent to investigate the possibility that your customer is a scam victim.

For the record, there is an exemption under RFPA where the bank suspects illegal activity. You may report those instances. You should probably have 'reasonable' suspicion.

We had this recently and even had an off duty police officer there to escort the customer and his funds if the customer wanted. The officer was there to at least show him out of the bank.

A CTR is required, but I agree with the others that if there is no crime, what is the purpose of the SAR? While unusual for us, and you, it isn't illegal.

In our case that local PD thought we were nuts. That happens all the time, they told us.

I think that how concerned you should be about the customer taking cash depends on other factors. :- Is the withdrawal the bulk of his assets, or does he have another $1m+ on deposit? Is your bank branch in an urban or rural area? Do you know what his business is? Is he a knowledgable businessman or someone who inherited a fortune? .... recently? Does he routinely make his own investment decisions, or does he rely on financial advisors?

If nothing else, the very least I think that you should do is to warn him, in the presence of another bank employee, that taking such a large amount of cash personally is risky, that you advise against it, and that once he has taken the cash off the counter/desk that it is his responsibility.

I've been reading too much Homeland Security stuff. Is there a chance that he's taking the cash because he's concerned about terrorist attacks affecting the bank?

Also, was he willing to wait for several days when he asked for the cash, or did he want it right away? Scammers usually want the money as quickly as possible, before their mark can come to their senses.

BINGO! The reason for the withdrawal (we were able to get the info from the wife) is the heightened alert. They are concerned that they could not get cash if the Fed Reserve Bank is hit (as if there's only one). They were offered a security escort. We were originally concerned that they might be the victims of a scam - not unknown around here. Thanks for all of your input.

Maybe since they lowered the "color of the day" this afternoon to yellow from orange, they will now reconsider.

Sorry - I was being a little facetious. They did lower the alert level today back to yellow - I just think that people are going to become deaf to the "wolf" cry. I think that it's the government's lame attempt to do something in case any other disaster happens so they can say "we warned you". It's like all the airport security - it's still inconsistently enforced and most of it is just a placebo to make the general public feel safer while being a heck of an inconvenience for frequent flyers.

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it's still inconsistently enforced and most of it is just a placebo to make the general public feel safer while being a heck of an inconvenience for frequent flyers.

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The inconsistency remark reminds me when I had to go to MN back in Nov. We have to leave on Sun, but I had not shaved either Sat or Sun. Here I am 6'2, 235 lbs in a pair of jeans, a sweat shirt, my B.A.S.S. fishing cap and 2 days unshaven. The person I go with is about 5'8' 140 lbs soak and wet with his pockets full of change.

When he picks me up he's in nice "business/casual" attire.

I go through the line ahead of him in Indy and Chicago. He gets checked (unloading his suit case, being wanded, having to take his shoes off, the whole 9 yards) both places. On the way back, I'm clean shaven business/casual and so is he. Again I go through the lines ahead of him in Minneapois and Chicago and again he gets checked both times. Never did figure this one out. At least they were consistant with him.

My bank had a policy against cash in safety deposit boxes (when I used to open the darned things) so recommending that course of action might be against policy.

I have assisted clients in taking large sums from a branch. I'd advise you make an effort to take them into a quiet room to do your count with dual controll of course. I always worried about counting out cash in an open place then sending folks on their merry way.

Folks:

Great discussion . . . and I'm glad that you resolved the situation. Here're a couple of other points to consider for future events:
1. Before you release any money, call your local law enforcement agency -- preferably talk with a detective who handles financial crimes -- and ask if the agency has received other, similar reports that involved a fraud.
2. Have your legal counsel create a "waiver of responsibility" document that the account holder must sign before receiving the money, that releases the institution from all liability involved with this unusual transaction.
3. Have an institution officer explain several of the current scams to the account holder -- and then witness the signature on the "waiver of responsibility" document.
4. The institution's responsibility doesn't necessarily end when the account holder receives the money -- it usually ends when the person is no longer present on the institution's premises and is back on public property.

To add to Dana’s comments:

Another step in performing any large withdrawal of cash is to develop a letter that outlines the type of scams that can be perpetrated against your customer. This letter should state that you have explained the bank examiner scheme, pigeon drop scheme or any other confidence games to your customer and that your customer has been advised about the safety issues. This letter as a matter of procedure would have to be signed by your customer to make the withdrawal. If anything should happen and the bank is sued you can prove the customer was warned. I would have legal counsel review the letter before implementing this procedure.

Good points, Dana, but where do you draw the line? ... and why don't customers receiving lesser amounts of cash get the same protection? ... and if I lower my threshhold to include smaller amounts, what about lesser and lesser amounts?

This whole discussion sounds very Y2K-esque. At that time, many banks made the decision that they were not willing to provide an escort for every panic-stricken customer, so they chose to provide NO escorts for anyone.

Richard:

Thanks for causing me to clarify my suggestion. The amount of money involved -- alone -- shouldn't dictate the response. I always look at the totality of circumstances, including the:
1. Customer's history with the institution;
2. Account's transaction history;
3. Comments made by the customer;
4. Customer who is accompanied by an unknown person; and
5. Customer's request for cash, instead of a negotiable document.

As a police detective, I would occasionally be called by a local institution and asked to counsel a tight-lipped customer. An 82-year-old male customer ordered $80,000 in cash and he wanted to pick it up the following day. The bank called me and I met him at the bank -- and I tried to talk with the customer. I explained several scams and he didn't want to listen. He impolitely told me that his financial affairs were none of my business. He was right. He signed for the $80,000 and left the bank with the money in a canvas bag.

I assembled a surveillance team and we watched the customer's house for the rest of the day and all night. No one came to his door and he never left. He returned to the bank the following morning and re-deposited the entire $80,000 -- and I followed him in. When I asked him why he did this, he told me that he just wanted to spend "some alone time" with his money. He'd sat in his living room for several hours, just counting the money -- over and over again.

Go figure . . .

Dana Turner

They could have just passed the money to the person behind them and the last one redeposits it, hopefully for the first person.

But I wonder if this would be the same as a rumor. You know how you tell person 1 something and they tell it to 2, 3, etc. By the time it hits person 50 it is changed. Think that could happen with the money?

Personally, I like to put my savings on the floor and roll in it. It tickles when the pennies stick to your face. Then I put it back in the jar and I'm good for a while.

I take it all back.

That's what you get for "putting in your two cents' worth"!

Someone is watching way too much television. What happened to our freedom to do whatever we want with our money? Yes, banks must report (CTR), but suspicious activity, no way! Yes, an attempt to see if the customer is being taken is good customer service, but most of the stuff noted in this thread is across the line, freedomwise.