As BSA Officer, one of your Analysts presents you the following SAR narrative for your review:

Mr. and Mrs. Johnson own three convenience stores/gas stations in South Florida. The Johnsons are new customers to the Bank as of October 2016, when they opened a personal savings account and a HELOC loan.

When the account was opened, the Johnsons stated they would make cash deposits between $3,000 and $5,000 to the personal savings account every week as their compensation from the businesses. The first deposit to the account was $52,000 in cash and they made cash deposits as expected in November and December.

Beginning in January, the cash deposit amounts have increased, with several just below $10,000. They appear to be structured. Despite the many deposits, the Johnsons keep a small balance in the savings account because after every deposit a transfer is made to pay down the loan. The initial balance for the new loan on 11/10/16 was $100,000, the loan was paid to zero on 2/23/17.

Below is the list of cash deposits made since the account opening:

• 10/7/16 $52,000
• 11/8/16 $3,646
• 11/29/16 $5,500
• 11/30/16 $7,500
• 12/7/16 $8,000
• 12/15/16 $7,950
• 1/13/17 $10,000
• 1/17/17 $15,001
• 1/23/17 $9,980
• 2/6/17 $5,000
• 2/13/17 $9,999
• 2/14/17 $5,000
• 2/21/17 $9,500.

With this in mind, and being constructively critical, please:

• Identify 3 follow-up questions that you would like the Analyst to research or elaborate further on.
• For each of those 3 follow-up questions, explain to the Analyst why that additional information will be useful to law enforcement.

Answer rating: 100% (QA)

As the BSA Officer reviewing the SAR narrative here are three followup questions that you could ask the Analyst to research or elaborate further on 1 ... View the full answer