Weekly CTR Filed on Customer - File a SAR?

Answered by:

Question:

Should a SAR be completed on a customer that has had one CTR every week for the last 6 months?

Answer:

Not based on that fact alone. There has to be something suspicious about the activity to warrant a SAR filing. Do you suspect that the customer is structuring transactions to avoid CTR reporting? Does the once-a-week cash activity make sense with the customer's business? Do you know the source of the cash being deposited? Where is the customer using the deposited funds - foreign wire transfers, frequent ATM withdrawals, official check purchases, etc.?

First published on BankersOnline.com 12/17/07