Money laundering and SAR.

[coveredbridge]

SAR = Suspicious Activity Report.

Never expected this to happen to me or my family but my son was called into his bank to answer questions about suspicious activity on his account that may be money laundering.

In January I sold our car to a dealer a couple of weeks before we left the country, returning to England to live. The check was $14,000 which is above the $10k mobile check deposit limit and we no longer had a bricks and mortar place to deposit the check so I went into my son's bank with him and endorsed the check in front of a teller before he deposited it into his account.

He then used Transferwise to send the money into my bank account in England, and to avoid wire charges he sent 3 payments over a 4 week period using ACH. This triggered the SAR resulting in him being called into the bank. Apparently he should have explained to the Teller clearly what he was intending to do, or better still called the Bank as they only saw a large sum being deposited and then paid out in smaller chunks.

I have done this a lot last year, paying in large chunks of money from my brokerage, then sending lots of smaller payments to my bank in England.

I'm a little confused here...how do you know a SAR was filed on these transactions? The bank should not be disclosing a SAR filing to the customer. That would be in clear violation of AML regulations.

General Prohibition on Disclosure

Important to the usefulness of the reporting system is the general prohibition on​

disclosure imposed upon financial institutions. These entities are barred from disclosing SARs,​

or information related to the existence of SARs, to “any person involved in the transaction”
reported upon in the SARs.

 

[audreyh1]

So, your son deposited in cash ? Above $10,000, you need to fill up a form. It's an archaic regulation, but they say its to catch the drug dealers who transact in cash.

No, he didn't deposit cash, he deposited a $14,000 endorsed check.

 

[Car-Guy]

You don't need to fill out any forms to deposit more than 10k in cash, other than a deposit slip. The bank is responsible for filling out the CTR (and SAR if needed). They typically won't tell you about it unless you ask.

 

[Fedup]

There is a limit of $100k ACH transfer per day. I've done this on multi banks, for overseas it's GBP 100k per day.

 

[NW-Bound]

I guess I do not understand why the OP's son got suspected. It is only cash transactions that would be suspicious.

I have transferred large amounts of money (several hundred Ks) between my accounts. No problem, as long as the money is moved between institutions. People buying/selling RE move large amounts of money all the time. Nothing illegal or suspicious about it.

 

[audreyh1]

There is a limit of $100k ACH transfer per day. I've done this on multi banks, for overseas it's GBP 100k per day.

Some banks and credit unions impose a much lower limit on SCH transfers. For example, $5K limit per day is not uncommon.

 

[audreyh1]

I guess I do not understand why the OP's son got suspected. It is only cash transactions that would be suspicious.

I have transferred large amounts of money (several hundred Ks) between my accounts. No problem, as long as the money is moved between institutions. People buying/selling RE move large amounts of money all the time. Nothing illegal or suspicious about it.

The only thing I can think of is that funds were transferred to an overseas bank?

 

[NW-Bound]

The only thing I can think of is that funds were transferred to an overseas bank?

Yes.

Alan, the OP, did this himself earlier without any question from the authority. But Alan was moving money between his own accounts. This time, money was moved from his son's account in the US to Alan's account in the UK. So perhaps that's the difference.

 

[Fedup]

I guess I do not understand why the OP's son got suspected. It is only cash transactions that would be suspicious.

I have transferred large amounts of money (several hundred Ks) between my accounts. No problem, as long as the money is moved between institutions. People buying/selling RE move large amounts of money all the time. Nothing illegal or suspicious about it.

It must be multiple days, I believe the limit is $100k among US institutions. But I've deposit checks in multiple of $100k with no problem.

 

[Fedup]

Some banks and credit unions impose a much lower limit on SCH transfers. For example, $5K limit per day is not uncommon.

I think for Bank of America, I could only do it $1000 or so per day. This is from my experience transferring money to my kids. IIRC.

 

[brewer12345]

Yes.

But Alan was moving money between his own accounts. This time, money was moved from his son's account in the US to Alan's account in the UK. So perhaps that's the difference.

That would be my guess as well. These systems are purposely not disclosed to outsiders to make it harder to game the system, so no way to know for sure.

 

[brucethebroker]

I'm not sure the average bank teller, who is often under 30, if not more like age 22, is a good judge of normalcy. Sometimes they want to print my checking account balance on the receipt, and I've had young tellers exclaim, "Wow, you have lots of money in your account!". This when the balance was 3 thousand and change.

Yep, and that is when they want you to talk to their "investor advisor"....here come the annuities!!!

 

[Alan]

It was not cash, it was a check from the local VW dealer.

He transferred it in 3 chunks because $5k is the max fee free amount TransferWise allows, and he transferred it all to my bank in England, so everything was easily traced, although this was the first time he has done this.

To LOL!
He was just asked some questions, no forms to fill in. Just a friendly warning. At least they didn't freeze his account or anything worse, and this happened in January so it took a while.

 

[audreyh1]

It must be multiple days, I believe the limit is $100k among US institutions. But I've deposit checks in multiple of $100k with no problem.

Only some institutions allow their customers to do ACH transfers of $100K, many have lower limits. Some are quite restrictive.

And the OP couldn't use mobile deposit to deposit the $14k check. Many banks have limits on Mobile Deposit. Chase is $5K, for example.

 

[Alan]

And the OP couldn't use mobile deposit to deposit the $14k check. Many banks have limits on Mobile Deposit. Chase is $5K, for example.

Exactly. I didn't want to endorse the check and mail it to my bank since endorsing it essentially changes it to cash.

In 2011 while on a 7 month stay in England I received an unexpected bonus paper check of over $6k from the company I'd retired from the previous year. My son was picking up our mail and let me know what had arrived. After informing my employer and my bank I got him to mail the check to our US bank without my endorsing it and they did allow it to be deposited to my account. Otherwise I'd have to have him mail it to me in England, then I'd endorse it and mail it to my bank in the US.

 

[Alan]

Yes.

Alan, the OP, did this himself earlier without any question from the authority. But Alan was moving money between his own accounts. This time, money was moved from his son's account in the US to Alan's account in the UK. So perhaps that's the difference.

That would be my guess as well. These systems are purposely not disclosed to outsiders to make it harder to game the system, so no way to know for sure.

Precisely. It was me giving money to a 3rd party (even though he had the same last name as myself and it was a very traceable check for a car sale to a dealer) who then sent the exact same amount back to me in 3 payments to my account in a foreign country.

It was common for me last year to deposit a sum from my brokerage account, say $30k, to my own bank via ACH, then send that exact same sum via 4 payments of $7.5k to my UK bank via Transferwise to save on wire fees and get a much better exchange rate. (I've done enough ACH transfers with Transferwise for them to increase the limit to $7.5k)

 

[Amethyst]

Good grief! Was this a small-town bank, where the tellers routinely "josh" with the customers? Because a complaint to the bank manager would have been in order. This an extremely tasteless question from anybody, let alone a bank teller

One time I deposited a large check at the bank and the teller asked me "What are you planning on doing with all of this money?" I had absolutely no idea what to say to her. Shocking. It was over $100K, and I never got questioned.

 

[Walt34]

Exactly. I didn't want to endorse the check and mail it to my bank since endorsing it essentially changes it to cash.

I've been doing what is called "restrictive endorsements" for decades, learned about it in a finance class in high school. Write "for deposit only" in the section for the endorsement and then the signature. It can be made even more restrictive by specifying a bank and specific account number.

That way no one can cash it if you lose it.

 

[audreyh1]

I've been doing what is called "restrictive endorsements" for decades, learned about it in a finance class in high school. Write "for deposit only" in the section for the endorsement and then the signature. It can be made even more restrictive by specifying a bank and specific account number.

That way no one can cash it if you lose it.

When I do endorsements for Fidelity's mobile deposit they have you write language like "For deposit only in my Fidelity account" above your signature.

 

[Fedup]

I think that's what was taught to me at my ROP banking class years ago, maybe close to 40 years. So that's what I always write in the back of my mobile checks and my account number.

 

[Alan]

I've been doing what is called "restrictive endorsements" for decades, learned about it in a finance class in high school. Write "for deposit only" in the section for the endorsement and then the signature. It can be made even more restrictive by specifying a bank and specific account number.

That way no one can cash it if you lose it.

That is what I have been doing for many years but I never trust it. In the UK all bank issued checks are crossed with the words Account Payee printed on them and can't be exchanged for cash unless they are made out to "Cash".

In the instances when I am traveling for many months at a time I get my son to email me a photo of each check front and back and I apply my signature and words for mobile deposit. Except that one time in 2011 when the check was too large, I was a continent away and not due back until well after the 90 days the check would expire.

 

[Brat]

These $10,000 to $100,000 transactions seem like chump change. I wonder of Paul Manafort's cash purchases of real estate in New York City will get as much scrutiny and what bank didn't flag them.

 

[euro]

I've been doing what is called "restrictive endorsements" for decades, learned about it in a finance class in high school. Write "for deposit only" in the section for the endorsement and then the signature. It can be made even more restrictive by specifying a bank and specific account number.

That way no one can cash it if you lose it.

Agree - have been doing this for as long as I can remember

 

[Alan]

I think that's what was taught to me at my ROP banking class years ago, maybe close to 40 years. So that's what I always write in the back of my mobile checks and my account number.

Unless you use a special pen then checks that fall into the wrong hands such as being picked out of the mail can be "washed" where the ink is removed from the check leaving only the signature.

https://en.m.wikipedia.org/wiki/Check_washing

 

[MichaelB]

I've been doing what is called "restrictive endorsements" for decades, learned about it in a finance class in high school. Write "for deposit only" in the section for the endorsement and then the signature. It can be made even more restrictive by specifying a bank and specific account number.

That way no one can cash it if you lose it.

I don't think I've every endorsed a check without doing that. Signature, back, account#.