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-   -   Suspicious Activity Reports to the IRS when buying or depositing money orders. (https://www.flyertalk.com/forum/manufactured-spending/1438710-suspicious-activity-reports-irs-when-buying-depositing-money-orders.html)

TheChallenge Sep 4, 2013 3:17 pm


Originally Posted by PaulMSN (Post 21389226)
Not that similar, other than exchange of money. Casinos are always looking for cheats. The distrust factor has got to be way higher.

A casino cage is for all purposes exactly a bank. They have to follow the same laws, procedures, regulations that any bank would have to follow. The only difference is a casino cage has to also submit to additional regulations put into place by the individual state's gaming regulatory agency.

Casino are cheated by guests much less than you're led to believe. The cameras are really there for internal theft, hence why the back hallways have just as many as the public areas. I've seen more employees walked out in handcuffs for cheating a casino or fellow employees in one year than I've seen guests walked off property for cheating in ten years.

andyandy Sep 4, 2013 3:17 pm


Originally Posted by TheChallenge (Post 21389055)
Based upon my experience being someone who's actually worked in a job were I've had to file SARs, I'm going to continue to go about my approach. Easy, plausible answers to innocent questions, instead of trying to explain the entire airline mile arbitrage concept to every bank employee. It's hard enough trying to get people I know to understand the concept, and not think it's odd behavior.

I think that Andy2 's position is entirely consistent with his reply to your earlier post, TheChallenge. As he noted there:

I cringe when I read about someone refusing to provide the requested information to a teller or clerk, because I personally suspect that this type of information is more likely to get a follow up on the SAR. I have always been friendly and upfront when asked what I am doing - I am doing a transaction to get miles or maximize my cash back rewards, and the tellers seem to understand that.
Personally, I haven't been asked what I was doing since way back in the Direct Ship days. I explained what I was doing back then and the tellers at my branch know that I'm "the coin guy.". I've used the same branch of the same (regional) bank to do virtually all of my miles related banking. These days it's money orders, always made out to me, signed by me, and deposited into the same checking account. If asked, I'd tell them exactly what I was doing without any qualms. My pattern of activity may be unusual for the average customer, but it's not unusual for me. Because I'm known to the personnel at my bank, I'm not concerned about SARs. After all, FinCEN offers the following definition of "suspicious activity":
Suspicious activity is any conducted or attempted transaction or pattern of transactions that you know, suspect or have reason to suspect meets any of the following conditions:
-Involves money from criminal activity.
-Is designed to evade Bank Secrecy Act requirements, whether through structuring or other means.
-Appears to serve no business or other legal purpose and for which available facts provide no reasonable explanation.
-Involves use of the money services business to facilitate criminal activity.

It strikes me as prudent to let your bank know (when asked) what the legal purpose for a money order deposit is. Maybe you have to take a minute to explain what you're doing, but if you are able to visit the same branch consistently, you'll soon get everyone there trained. YMMV.

PaulMSN Sep 4, 2013 3:25 pm


Originally Posted by TheChallenge (Post 21389378)
A casino cage is for all purposes exactly a bank. They have to follow the same laws, procedures, regulations that any bank would have to follow. The only difference is a casino cage has to also submit to additional regulations put into place by the individual state's gaming regulatory agency.

Casino are cheated by guests much less than you're led to believe. The cameras are really there for internal theft, hence why the back hallways have just as many as the public areas. I've seen more employees walked out in handcuffs for cheating a casino or fellow employees in one year than I've seen guests walked off property for cheating in ten years.

Sorry, but they're not at all the same. The purpose is different, and that changes the atmosphere. I don't agree that your experiences at casinos are relevant to what transpires in a bank, and I still say that subterfuge is completely unnecessary.

TheChallenge Sep 4, 2013 3:31 pm


Originally Posted by andyandy (Post 21389382)
-Appears to serve no business or other legal purpose and for which available facts provide no reasonable explanation.

You seem to be missing the second part of the equation though, "and for which available facts provide no reasonable explanation." I gave the teller a reasonable explanation, a very plausible reason. It's not the tellers job to decide if the reason I give is truthful, it just has to be a reasonable explanation.

If you feel that the tellers at your bank will accept purchasing MO for airlines miles as an explanation, go ahead and do it. Unfortunately, I don't feel that's the case with the branches I go to.

TheChallenge Sep 4, 2013 3:46 pm


Originally Posted by PaulMSN (Post 21389427)
Sorry, but they're not at all the same. The purpose is different, and that changes the atmosphere. I don't agree that your experiences at casinos are relevant to what transpires in a bank, and I still say that subterfuge is completely unnecessary.

Well I guess we'll have to agree to disagree, I don't believe the purpose is any different. I believe they are actually exactly the same. I've also been told the same thing by bank branch managers and tellers who've been hired away to be cage managers and cashiers, they stated the job was exactly the same. Just a different title and work hours.

vagrants Sep 4, 2013 7:05 pm

Deleted

AnalystGuy Sep 5, 2013 7:32 am


Originally Posted by TheChallenge (Post 21389462)
You seem to be missing the second part of the equation though, "and for which available facts provide no reasonable explanation." I gave the teller a reasonable explanation, a very plausible reason. It's not the tellers job to decide if the reason I give is truthful, it just has to be a reasonable explanation.

If you feel that the tellers at your bank will accept purchasing MO for airlines miles as an explanation, go ahead and do it. Unfortunately, I don't feel that's the case with the branches I go to.

Yes, but you are still being untruthful and that might lead to issues later on if the back office reviews your account. You are assuming that scrutiny from the bank will only be generated from the front lines, but there is a lot of monitoring and reporting that is automated. We use software that imports and aggregates all of a person's deposits-cash, check, cash equivalent, etc. Cross certain thresholds or match certain patterns and your account comes up for review for both BSA/AML and/or fraud. We often inquire with the branch about certain customers or talk to them directly. If deceit is evident we are much more likely to escalate to filing or account closure.

andyandy Sep 5, 2013 7:49 am


Originally Posted by TheChallenge (Post 21389462)
If you feel that the tellers at your bank will accept purchasing MO for airlines miles as an explanation, go ahead and do it. Unfortunately, I don't feel that's the case with the branches I go to.

I agree that this is a YMMV situation. If I wasn't able to establish a relationship with tellers at a particular branch, it might get tiresome explaining the miles game every time. It might be more difficult to do in a big city or where there is more personnel turnover. Thing is, though, I really enjoy talking about the lengths I'll go to for miles. :D So, I'd probably launch into my evangelizing mode any time I was asked.

myndreamland Sep 6, 2013 10:14 pm

Got my first drama today. Local CU froze both my and my SO's account, without notice. Mint couldn't update my account and when I use the automated system, it said my account has a negative -1000 balance.

Went in branch, talk to personal banker. 5 minutes later, compliance came in. Told them about the mile game and gave them receipts showing purchases of MOs with debit cards, not with cash. Compliance seemed cool about it and an hour later, I got a call saying that they activated both our checkings.

However, I checked back online later and found out that the remote transfer and bill pay functions on both our accounts were still disabled. I don't know if they haven't enabled them back or if they decided to permanently disable those functions. Guess I'll know next Monday. Nevertheless, it was fun :D

tsmith12 Sep 7, 2013 5:59 pm


Originally Posted by myndreamland (Post 21402249)
Got my first drama today. Local CU froze both my and my SO's account, without notice. Mint couldn't update my account and when I use the automated system, it said my account has a negative -1000 balance.

Went in branch, talk to personal banker. 5 minutes later, compliance came in. Told them about the mile game and gave them receipts showing purchases of MOs with debit cards, not with cash. Compliance seemed cool about it and an hour later, I got a call saying that they activated both our checkings.

However, I checked back online later and found out that the remote transfer and bill pay functions on both our accounts were still disabled. I don't know if they haven't enabled them back or if they decided to permanently disable those functions. Guess I'll know next Monday. Nevertheless, it was fun :D


How many MOs were you depositing?

myndreamland Sep 7, 2013 6:15 pm


Originally Posted by tsmith12 (Post 21405827)
How many MOs were you depositing?

I spread my MO across 5 pairs of accounts to stay under the radar so it's only 12k for 2 months on 2 accounts or 1 MO for each account each week. Guess that my small local CU is pretty vigilant with irregular activity. The compliance person didn't even have to look at my account to know who I am.

farwest101 Sep 7, 2013 8:07 pm


Originally Posted by myndreamland (Post 21405876)
I spread my MO across 5 pairs of accounts to stay under the radar so it's only 12k for 2 months on 2 accounts or 1 MO for each account each week. Guess that my small local CU is pretty vigilant with irregular activity. The compliance person didn't even have to look at my account to know who I am.

That's peanuts. Get a different bank.

tsmith12 Sep 8, 2013 12:51 am


Originally Posted by myndreamland (Post 21405876)
I spread my MO across 5 pairs of accounts to stay under the radar so it's only 12k for 2 months on 2 accounts or 1 MO for each account each week. Guess that my small local CU is pretty vigilant with irregular activity. The compliance person didn't even have to look at my account to know who I am.

I wrote this earlier also but to me, CUs and small regional banks are more vigilant and suspicious than big bank(s) If this was Chase/Bofa, I have a feeling 12K over 2 months/2 accts would not have raised any flags.

ma91pmh Sep 8, 2013 6:58 am


Originally Posted by tsmith12 (Post 21406941)
I wrote this earlier also but to me, CUs and small regional banks are more vigilant and suspicious than big bank(s) If this was Chase/Bofa, I have a feeling 12K over 2 months/2 accts would not have raised any flags.

$12k over two days not two months ought not to raise flags if you are doing it right

AlohaDaveKennedy Sep 8, 2013 8:04 am

This all sounds so nice, but admit it Cardinal AG, the reality is that you burn heretics at the stake first, then run the analytics later to clear your conscience. :D

And that "talk to them directly business" typically only takes place over hot coals or the rack.:D




Originally Posted by AnalystGuy (Post 21392815)
... We use software that imports and aggregates all of a person's deposits-cash, check, cash equivalent, etc. Cross certain thresholds or match certain patterns and your account comes up for review for both BSA/AML and/or fraud. We often inquire with the branch about certain customers or talk to them directly. If deceit is evident we are much more likely to escalate to filing or account closure....



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