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A pattern of cash deposits below the CTR reporting threshold generated a SAR filing by a U.S. institution. Deposits were made daily to the account of a foreign currency exchange totaling $341,421 for approximately a two-and-one-half-month period. During the same period, the business initiated 10 wire transfers totaling $2.7 million to a bank in the United Arab Emirates. When questioned, the business owner reportedly indicated he was in the business of buying/selling foreign currencies in Iran, the Persian Gulf States, and other countries in the Middle East, and his business never generated in excess of $10,000 a day. CTRs for three years reflected cash deposits totaling $137,470 and withdrawals totaling $29,387. The business owner and the cash-out transactions were conducted by nationals of countries associated with terrorist activity. Another U.S. depository institution filed a SAR on this person for an $80,000 cash deposit, which was deemed unusual for his profession. He also cashed two negotiable instruments at the same depository institution for $68,000 and $16,387 according to CTR filings. Wire Remittance Company

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