Which Transaction Requires SAR/STR Filing?

A

Sure, I'd be happy to explain this question in detail.

In general, a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) is filed when there is reason to believe that a transaction or activity may involve money laundering or other illegal activities. The decision to file a SAR/STR depends on a number of factors, including the size and frequency of the transactions, the source of the funds, and any other relevant information.

Let's take a closer look at each of the options provided:

A. A small business owner deposits checks totaling $9,950 USD on a daily basis without providing a legitimate purpose.

This transaction may be considered suspicious because it involves a small business owner making daily deposits just below the $10,000 threshold for Currency Transaction Reports (CTRs), which are filed by financial institutions to report large cash transactions. Additionally, the fact that the business owner is unable to provide a legitimate purpose for the deposits could suggest an attempt to structure transactions to avoid detection. As a result, this transaction may warrant a SAR/STR filing.

B. A small business owner deposits $25,000 USD in cash proceeds with a business equipment bill of sale.

This transaction may also be considered suspicious because it involves a large cash deposit without a clear business purpose. While it is possible that the business owner legitimately sold equipment for cash, the lack of documentation or other evidence to support the transaction could raise concerns about possible money laundering or other illegal activities. As a result, this transaction may warrant a SAR/STR filing.

C. A national food-chain restaurant with multiple cash transactions at various branch locations.

This option is somewhat vague, as it does not provide specific details about the nature or volume of the cash transactions. However, it is worth noting that businesses that primarily deal in cash, such as restaurants, can be at higher risk for money laundering and other financial crimes. If there is evidence to suggest that the restaurant is knowingly or unknowingly facilitating illegal activity, then a SAR/STR filing may be warranted.

D. A national food-chain restaurant makes multiple, anticipated cash transactions that are above the daily reporting threshold.

This option is similar to option A in that it involves structuring transactions to avoid reporting requirements. If the restaurant is making multiple cash transactions just below the $10,000 CTR threshold, this could suggest an attempt to avoid detection. However, if the transactions are above the reporting threshold and are therefore being reported by the financial institution, then a SAR/STR filing may not be necessary unless there are other red flags or concerns.

In summary, the transactions that are most likely to result in a SAR/STR filing are those that involve large cash deposits or frequent cash transactions without a clear business purpose or legitimate explanation. However, the specific circumstances of each transaction will need to be evaluated on a case-by-case basis to determine whether a filing is warranted.