Money laundering and SAR.

[Alan]

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.

 

[Big_Hitter]

I always tell the teller what I'm doing when I deposit or withdraw that much cash.

 

[ivinsfan]

I always tell the teller what I'm doing when I deposit or withdraw that much cash.

What good does it do to mention to the teller, a person could feed the teller any load of bull.

In fact in this day and age 10K is a tiny amount of money and the limit should be higher in IMO...This reminds me of leaving Wal-Mart or Sams Club with your purchases and proving to them that you "DIDN'T" steal it.

 

[Big_Hitter]

What good does it do to mention to the teller, a person could feed the teller any load of bull.

well it's worked for me

 

[Alan]

I always tell the teller what I'm doing when I deposit or withdraw that much cash.

He/we did tell the teller what we were doing, but obviously not in enough detail, and it did seem a relatively small amount of money. It was also not cash, the check was from a big VW dealer in the town.

 

[easysurfer]

Avoid using those $9,999.99 deposits .

 

[brewer12345]

The breaking up of a larger sum looks like "structuring" in anti money laundering (AML) parlance. Frankly, I am surprised you have not been questioned before, but the third party check into your son's account that was then sent back to the third party overseas is probably what triggered it. Various regulators (especially the OCC) have been coming down heavy on AML issues over the last 5 to 10 years, so this sort of thing is probably here to stay for you as a banking customer.

 

[ivinsfan]

well it's worked for me

but that's typical government rules, if you were laundering money, you'd probably have a story ready to explain it. If the point of contact at the bank can stop an inquiry they can be bought off too. Not all criminals are stupid, in fact many of the white collar are pretty darn smart

 

[Alan]

The breaking up of a larger sum looks like "structuring" in anti money laundering (AML) parlance. Frankly, I am surprised you have not been questioned before, but the third party check into your son's account that was then sent back to the third party overseas is probably what triggered it. Various regulators (especially the OCC) have been coming down heavy on AML issues over the last 5 to 10 years, so this sort of thing is probably here to stay for you as a banking customer.

Thanks for that background info.

In January we bought a house and when I transferred the balance of £275k from my U.K. bank to the law firm I had to do it by phone and was asked a few questions which they said was to do with anti money laundering. (I had moved the money from the USA over the previous 9 months in much smaller amounts)

 

[easysurfer]

About a year ago, I helped out a niece and wrote a check for about $11K to help buy a used car. My sister (her mom) paid me back but all in cash (mostly fresh 100's, 50's from bank withdrawals).

The $11K check I wrote didn't raise an issue since the check is traceable. I probably could've deposited the cash in my checking account but feel like I'd be under suspicion with all the new bills.

So, I've been spending the bills mostly when buying groceries (bills get examined each time to make sure I'm not passing counterfeit).

The world we live in, "Guilty until proven innocent" .

 

[Car-Guy]

Never been asked by a bank or any financial institution why I'm depositing or withdrawing over 10k in cash in any single transaction. I would not tell them if asked since it's none of their business. I'm sure I've had numerous CTR's filed on me and maybe even a few SAR's. Never had any calls, letters, etc from anyone. No big deal.

 

[MrLoco]

Never been asked by a bank or any financial institution why I'm depositing or withdrawing over 10k in cash in any single transaction. I would not tell them if asked since it's none of their business. I'm sure I've had numerous CTR's filed on me and maybe even a few SAR's. Never had any calls, letters, etc from anyone. No big deal.

Well.....maybe so far you haven't had any calls or letters from anyone.

FINCEN is the Govt. agency that receives CTR's and SAR's?

The FINCEN - Financial Crimes Enforcement NEtwork. FINCEN will share the reports with that Govt. agency we all love to hate... the IRS! (Sometimes even the DEA). Multiple CTR/SAR can only increase the chances of an IRS audit. I would not suggest you tell the IRS agent conducting your audit that the movement of large amounts of cash is "None of their business." Cause I guarantee they will make it their business .....and make your life miserable.

 

[euro]

What good does it do to mention to the teller, a person could feed the teller any load of bull.

In fact in this day and age 10K is a tiny amount of money and the limit should be higher in IMO...This reminds me of leaving Wal-Mart or Sams Club with your purchases and proving to them that you "DIDN'T" steal it.

bingo!

 

[Car-Guy]

Well.....maybe so far you haven't had any calls or letters from anyone.

FINCEN is the Govt. agency that receives CTR's and SAR's?

The FINCEN - Financial Crimes Enforcement NEtwork. FINCEN will share the reports with that Govt. agency we all love to hate... the IRS! (Sometimes even the DEA). Multiple CTR/SAR can only increase the chances of an IRS audit. I would not suggest you tell the IRS agent conducting your audit that the movement of large amounts of cash is "None of their business." Cause I guarantee they will make it their business .....and make your life miserable.

Duh, of course the IRS knows.

 

[NW-Bound]

The FINCEN - Financial Crimes Enforcement NEtwork. FINCEN will share the reports with that Govt. agency we all love to hate... the IRS! (Sometimes even the DEA). Multiple CTR/SAR can only increase the chances of an IRS audit. I would not suggest you tell the IRS agent conducting your audit that the movement of large amounts of cash is "None of their business." Cause I guarantee they will make it their business .....and make your life miserable.

+1

The police in many places has been known for seizing large amounts of cash, without charging the cash holders with any crime activity. Sounds terrible, does it not?

On a bright, clear morning in April 2013, two professional poker players from California were heading west on Interstate 80 in rural Iowa when they were stopped by two Iowa State Troopers.

Before that stop was over, the officers had seized $100,000, which the men said was money to play poker. The troopers also called ahead to California authorities, who raided the men's homes and ultimately indicted one of them, John Newmerzhycky, on a charge of illegal possession of drug paraphernalia.
​

See: States seize cash, property from motorists - CNN.com

See also: Civil Forfeiture in the US

Excerpt: In May 2010 a couple was driving from New York to Florida and they were stopped by police because of a cracked windshield. During questioning, the officer decided that $32,000 cash in the van was "probably involved in criminal or drug-related activity", seized it, shared it with federal authorities under equitable sharing. The victim hired a lawyer to get back the seized money who urged settling for half of the seized amount, and after the lawyer's fees, the victim got back only $7,000.​

 

[LOL!]

OK, Alan's son was called into his bank (nice fellow, I've met him), but did the bank give him milk and cookies or coffee and donuts? What was the outcome? Did he have to sign a form that the bank folks filled out? Was everybody satisfied? Or is he going to jail?

 

[Car-Guy]

The police in many places has been known for seizing large amounts of cash, without charging the cash holders with any crime activity. Sounds terrible, does it not?

Yes it does. It's not hard to find such stories in the local news around here especially in some of the small towns with known speed traps. I've often heard it called "Civil forfeiture or Civil seizure".

I know of one case a few years ago, not to far from here, that a fellow was stopped one night (he was speeding) and had over 40k confiscated. He told the cops he won the money at a casino but I guess they didn't buy it. (There's more to this story) I understand it took him over a year to get his money back. (w/o interest I'm sure)

 

[GrayHare]

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.

 

[meierlde]

Of course IMHO carrying such large amounts of cash is a huge risk of a mugging and criminal confiscation of the cash. The 100k for gambling is a bit suspicious as I suspect if the casinos will allow you to wire money to the casino to pick up when you arrive. Of course then you might have to duck out of private car transactions, but as documented in another post they have other risks as well. (and indeed a cashiers check does work as well as cash since in that case the check is really against the issuing bank, your account has already had the amount deducted.

 

[Ready]

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.

That's pretty bad! I would be very annoyed if that happened to me.

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.

 

[FUEGO]

I used to do a series of $8,000 cash deposits spaced days or weeks apart, just $2,000 under the reporting requirements. I always asked the teller if I needed to disclose anything regarding the cash deposits in order to avoid accusations of structuring (learned about it during law school). The answer was always no.

So far, so good. No prison time.

 

[audreyh1]

I'm a little surprised for the OP because these were not cash transactions.

I assume the reason he did it it 4 chunks was because his bank has ACH daily and/or monthly transfer limits?

Checks and electronic transfers all can be tracked. Why would "staggering" matter?

DH deposited a large (>$50K) check once, the teller had to get the bank manager to approve the deposit. But no questions were asked.

 

[W2R]

When I bought my Dream Home in cash, first I received several large sums from Vanguard via ACH, although I don't think there was any upper limit for the amount of on ACH transfer to my bank. Then I had a certified check created, for me to carry to the real estate closing.

No question at all, although I made a point of sitting down and explaining everything to the bank during the week before closing. I thought they would figure I was some sort of international drug smuggler or something, but no. They said they do this all the time. I don't recall signing anything saying what it was for.

 

[Souschef]

Avoid using those $9,999.99 deposits .

I pulled a bunch of equity out of my rental using an HELOC. I did it in increments of $6500 to $8500.

 

[cyber888]

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.