CASE STUDY ON STR/SAR

Mr. X, a company director and shareholder of a local

sports club currently in administration, has held both
personal and business accounts with the bank for a
considerable number of years. Mr. X is well known to staff
and is something of a local celebrity. On the same day that
a credit of BDT18,50,000 was received in his personal
account, Mr. X approached the bank to request a
withdrawal of BDT 1500,000 in cash, and issued two
cheques in a total sum of BDT 350,000 to his business
partner Mr. Y. Mr. X was advised that such an amount of
cash would need to be ordered, but that it could be made
available in two working days.
 CASE STUDY ON STR/SAR ( CONT.)

 The teller suggested to Mr. X that this sum of

money could be transferred by more secure
methods than cash withdrawal. Cash Officer also
gone through his TP and found that cash
withdrawal data was absent in his TP and only
contains Fund Transfer through RGTS & EFT.
Mr. X declined this suggestion, stating that he did
require the sum in cash, and advised that the
money had come from his sports club. Finally,
manager of the branch refrained from such
transactions.
CASE STUDY ON STR/SAR
Issues:

What was the basis for suspicion, if any?

Should a SAR/STR has been submitted?

Was the Cash Officer being asked to conduct a prohibited act

or circular?

If a report were to have been submitted, how may this have

impacted upon the bank?

What were the risk factors?

How could the bank/reporter have mitigated against any

risks?
 CASE STUDY ON STR/SAR

Ms. Roksana held a bank account which had seen

sporadic use throughout her five year relationship
with the Gulistan bank Ltd. When in use, the pattern
had been that of multiple cash deposits, on the same
day, which were paid in through a number of local
branches. However in a three month period the
account had received heavier use than normal,
receiving deposits totalling BDT 50,00,000 in cash
and BDT 60,00,000 in cheques, a number of which
were for BDT 10,00,000 – BDT15,00,000 at a time.
 CASE STUDY ON STR/SAR

These funds had then been withdrawn by

cheque and direct debit payments. Initial
funds credited to Ms. Farida’s account, in the
sum of BDT 25,00,000, which she had advised
bank staff were the proceeds of a property sale,
had been subsequently transferred to an
account she had recently opened in the name
of Company Y.
CASE STUDY ON STR/SAR ( CONT.)

 When asked if a cash transaction of BDT 25,00,000

could be paid directly into the account of Company Y,
Ms. Roksna was adamant that the funds should be first
processed through her personal account. Two bankers’
cheques had been debited from Company Y’s account,
one in the sum of BDT15,00,000 to a solicitors firm and
the other for BDT 10,00,000 to a development company.
On the other hand , TP does not contain above
mentioned Transactions under any circumstances. It is
publicly available information that client has a good
relation with IP and Govt high officials.
 CASE STUDY ON STR/SAR
Issues:

What was the basis for suspicion?

Should a SAR/STR have been submitted?

What were the risk factors?

How could the bank/reporter have mitigated

against any risks?
CASE STUDY ON STR/SAR
 Amin & Co. Ltd in accordance with the data available
at “Bank Gulshan Ltd " is a retailer of jewelry and
precious metal. Based on the bank's observation, this
company has a slow growth. Usual transfer to and
from the account of Amin & Co. Ltd from a number of
individuals is a multiple amount of BDT 1.00 lac and
ranges from BDT 10.00 lac to BDT 50.00 lac. Transfer
out is also conducted in a routine manner to two
"company executives" of Amin & Co. Ltd in a
relatively enormous amount namely ranges from BDT
20.00 lac to BDT 80.00 lac. Cash withdrawing is also
performed frequently by the employees of Amin & Co.
Ltd and the amount reaches of 5.00 Crore BDT in a
month. The aforementioned mutation pattern draws
the attention of “Bank Gulshan Ltd” officials.
SUSPICIOUS INDICATORS
Customer's account activity is inconsistent with the fact that
customer's business grows slowly.

Transaction patterns as reflected by transaction amount and

frequency involving some persons do not comply with customer's
business characteristics.
Routine transfer to two "company executives" of Amin & Co. Ltd in
a large amount has unclear relation with customer's business.

Cash withdrawing in a relatively large amount frequently having

unclear relation with customer's business often occurs.
 CASE STUDY ON STR/SAR
Bank Gulistan Ltd, in November 2017, opened saving
accounts for 10 new customers most of whom work as
private entrepreneurs with the average income of
BDT 25,000.00 to BDT 50,000.00 per month. Within a
month, the ten accounts simultaneously receive Tk.
5.00 lac each time through RTGS from a senior
regional official through various banks. Each of
account holders withdrew some cash through ATM in
a several phases within a relatively short period and
they left only thousand BDT in their accounts.

Officials of Bank Gulistan Ltd checked the addresses

of the account holders and it found that they provided
false addresses. There is information that one of the
ten account holders has been arrested by the DMP
due to fraud cases.
CASE STUDY ON SAR/STR
Suspicious Indicators
Accounts were opened for the purpose of receiving funds
in several phases and the funds were withdrawn in a
relatively short period.
Transactions were conducted without clear reasons.

Transactions amount and frequency does not comply with

customer's income profile.

The withdrawal was conducted in cash through ATM in a

reasonable high frequency and maximum amount so that
the balance is almost gone

One of the customers was arrested by the Police due to

fraud cases.

The customers provided fake addresses.