The Teacher, the Board Member, and the Request to Close the Alert

Decision: file.

Reasoning - the aggregation, not any single transaction, is the case

• Volume and velocity are inconsistent with the profile: $61,000 in cash over eight weeks against $3,900 monthly salary. Even a modest resale business would not naturally produce repeated round-sum cash deposits of this size.
• The deposit pattern is consistent with structuring: amounts between $6,000 and $9,800 sit below the $10,000 reporting threshold, and the split across four branches reduces the chance any single branch sees the full picture.
• Source-of-funds is unexplained and undocumented. An assertion of family savings plus an online business, with nothing produced, does not close the gap - it is a claim that itself needs corroboration.
• The incoming LLC wires are a third-party source unrelated to salary or to the stated business, and the near-total onward movement of $88,000 to a title company adds a rapid-pass-through and real-estate leg.

What the narrative must contain

• Every cash deposit with date, amount, branch and teller-identifying information; the aggregation calculation stated explicitly.
• Both incoming wires with originator, LLC name, and any registration findings.
• The outbound wire, payee, property state, and whether title records show the customer, a relative, or a third party as purchaser.
• The customer's explanation, verbatim where possible, and precisely why it was insufficient.
• The relationship manager's request and the board-member relationship, recorded neutrally as a fact.
• Nothing in the narrative that identifies the person who requested closure, and no contact with the customer about the filing.

File within the framework's deadline (30 days when a subject is identified) and record the decision and rationale even if the conclusion had been no-SAR.

Handling the request

• Treat it as information, not instruction. The decision to close an alert belongs to the AML function; a business-line request cannot convert an unverified assertion into verified status.
• Document the request contemporaneously: who asked, when, and on what basis. This protects both the analyst and the institution if the file is later examined.
• Do not confirm or deny to the relationship manager that any report has or will be filed. The prohibition on disclosing a SAR exists precisely because the business line is the most likely source of a tip-off.

Governance steps

1. Escalate to the BSA officer immediately, with the file.
2. Flag the personal relationship between the customer and a board member as a conflict of interest. The board member should be recused from any discussion of the case, and the audit committee or independent directors should be informed that the situation exists - without disclosing reportable information.
3. Ask whether the relationship manager has any other accounts connected to this customer, the LLC, or the board member, and review those for similar activity.
4. Consider whether the request reflects a pattern: if this RM has repeatedly sought closures without documentation, that is a conduct and training issue for the control environment, not a one-off.
5. Log the escalation and its outcome in the case file; the record of how the institution resisted internal pressure is as important to an examiner as the filing itself.

Before finalising - corroborate or contradict

• The LLC: registry search, formation date, officers, registered address shared with other entities, whether it is in a different state or country from the customer.
• The property: title and deed records - is the purchaser the customer, a relative, or an unrelated third party? A third-party purchaser changes the case substantially.
• The resale business: state business registration, marketplace seller accounts, tax filings, any evidence of trading activity.
• Related accounts: joint accounts, accounts at the same address, the board member's accounts if any link exists, accounts that received wires from the same LLC.
• Open source and adverse media on the customer, the LLC and its principals.
• A written source-of-funds request with a stated deadline - the oral explanation with no documents is the weakest element of the file.

After filing

• Place the customer on enhanced monitoring for at least 90–120 days and set a continuing-activity review so a second filing captures ongoing transactions.
• Do not exit the relationship in a way that signals the filing - an abrupt closure the week after a SAR is a classic tip-off indicator. Sequence the exit on ordinary commercial grounds and document the business rationale.
• If the EDD response remains inadequate, exit is appropriate and should be approved at BSA officer level, with the account closed, not merely frozen.
• If the property turns out to be held by a third party with no relationship to the customer, escalate: that is a nominee-purchase indicator and may warrant a separate filing on the third party.