Introductory BSA AML Examiner School Manual Palm Springs 2019

BSA: 31000041257613

BSAR Transcript BSA: 31000041257613 and DCN:

Narrative

A SUPPLEMENTAL SAR IS BEING FILED ON BANK CUSTOMERS DEBBIE SMITH, DBA DEBBIE’S FINE CLOTHING,

MARTHA E. JONES AND SUE JUNE FOR SUSPICIOUS CASH DEPOSITS AND CASHIER'S CHECK PURCHASES

INVOLVING PERSONAL CHECKING ACCOUNT #160956488 (OPENED 11/13/2012) AND BUSINESS CHECKING

ACCOUNT #160378154 (OPENED 11/26/2013). DEBBIE SMITH IS THE PRIMARY SIGNER ON BOTH ACCOUNTS.

MARTHA JONES IS THE SECONDARY SIGNER ON ACCOUNT 160956488, SUE REGERT IS THE SECONDARY

SIGNER ON ACCOUNT 160378154. BOTH ACCOUNTS ARE MAINTAINED BY THE ATWATER BRANCH (#160). SARS

WERE PREVIOUSLY FILED ON 03/19/2013 AND 06/14/2013 TO REPORT $70,855 IN SUSPICOUS ACTIVITY BETWEEN

12/14/2013 AND 06/13/2013. A THIRD SAR WAS FILED 10/22/2013 TO REPORT $29,400 IN SUSPICIOUS CASH

DEPOSIT AND CASHIER'S CHECK ACTIVITY BETWEEN 07/01/2013 AND 10/21/2013. A ROUTINE VIEW OF THE

MONETARY INSTRUMENT SALES LOG AND ACCOUNT ACTIVITY COVERING 10/22/2013 THROUGH

01/23/2014 WAS PERFORMED. DURING THE REVIEW PERIOD THERE WERE 20 CASH DEPOSITS TOTALING

$91,526 MADE TO THE ACCOUNTS AT THE ATWATER BRANCH IN AMOUNTS BETWEEN $370 AND $9,900.

FOLLOWING THE DEPOSITS, A CHECKING WITHDRAWAL SLIP WAS EXCHANGED TO PURCHASE CASHIER'S

CHECKS. BASED ON THE FREQUENCY AND AMOUNT OF CASH DEPOSITS IT APPEARS THE TRANSACTIONS WERE

STRUCTURED IN ORDER TO CIRCUMVENT THE REPORTING REQUIREMENT ESTABLISHED UNDER THE BANK

SECRECY ACT. THE FOLLOWING ACTIVITY WAS OBSERVED: PERSONAL ACCOUNT #160956488 HAD 11 CASH

DEPOSITS TOTALING $36,311 AND 7 CASHIER'S CHECKS TOTALING $36,500.53 WERE PURCHASED. BUSINESS

ACCOUNT #160378154 WAS OPENED ON 11/26/2013 WITH A $200 TRANSFER FROM ACCOUNT 160956488. THIS

ACCOUNT HAD 9 CASH DEPOSIT TOTALING $55,215 AND THERE WERE 10 CASHIER'S CHECKS TOTALING

$56,194.93 PURCHASED. CASHIER'S CHECKS WERE PAYABLE TO THE FOLLOWING: LA IDOL, AFFLICTION, MISS

ME, OR ROCK REVIVAL. THIS SAR IS BEING FILED ON THE BASIS THAT THE CASH DEPOSITS APPEAR TO BE

STRUCTURED. THE BANK WILL CONTINUE TO MONITOR THE ACCOUNTS AND WILL FILE A SUPPLEMENTAL SAR IF

REQUIRED. NO LOSS WAS INCURRED BY BANK. THE FOLLOWING SUPPORTING DOCUMENTATION UTILIZED IN

THE PREPARATION OF THIS REPORT IS MAINTAINED BY THE BANK BSA DEPARTMENT AND IS AVAILABLE UPON

REQUEST: GLOBAL VISION CASH ACTIVITY PRINTOUT, SIGNATURE CARD, MONTHLY STATEMENTS OF AFFECTED

ACCOUNT(S) AND COPIES OF THE REFERENCED TRANSACTIONS (WITH OFFSETS, IF APPLICABLE). PLEASE

CONTACT RC, AVP/BSA MANAGER AT (707)863-6622

Page 1 The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.