I have a customer that is quite wealthy and routinely cashes checks for $8,000 a few times a week. Last week he came into the bank 4 days in a row and cashed his $8,000 checks (consecutively numbered). He stated that he is going away for his 50th birthday and this is to have cash on hand to entertain the guests he has invited to the celebration and pay for expenses. We don't doubt that he is celebrating his birthday or that he will foot the bill. My problem is, this is normal activity for him that he conducts on a yearly basis, although last year it wasn't on consecutive days. To make matters worse, his lucky number is 8 (hence the $8,000 increments). Naturally, nobody has ever provided the customer the "Notice to Customers- CTR Guide", although they will be doing now, after the deed is done by my department. I honestly don't feel the guy is structuring. $8,000 to him is like $20 to a normal person. Any way out of this?

In my opinion it's structuring plain and simple.
Let me guess, his other lucky number is 9?

Prior thread.

Structuring does not differentiate between wealthy and non-wealthy.

If the purpose was to avoid the filing file away.

he took $32,000 over 4 days...for a trip he is planning in the future...I see no other answer except structuring to avoid reporting

I'd agree with Happy. (he's a smart guy, you know)

You know the purpose, all the cash is for one thing, there's no logical (magic numbers aren't logic to me) reason to transact this way. If he did four consecutive (why not eight, to be consistent? )transactions during the same visit of $8,000 each, and he wanted the bills in bundles of eight bills at a time, folded eight ways, fine, I'd write that off, but this would fall into the structuring category on my end.

Resistance to defensive filing is futile; you will be assimilated.

As an auditor I usually do not comment on a specific case but gently nudge, but:

I do not see this as defensive in the least. He took out 32,000 with the intention to use it all in the same time, place and purpose (only one of the 3 is needed) and he did it in a means to avoid reporting. lucky number is 8 (and wealth) is nothing more than a Red Herring.

Sorry, cut and dry IMO.

OP here,

Thank you all for your comments. I wasn't suggesting that I wouldn't file, was just making an observation that the customer routinely draws $8,000 increments at least a few times a week. This time it just happened to be 4 times in one week!!! It would just be nice if there could be some common sense applied to why we file SAR's. The guy isn't laundering money, dealing drugs, or engaged in human trafficking. Just a rich guy that likes to carry a lot of cash. He paid his tailor $4,000 for the suit for the party, and $30k for the caterer!! Just for a weekend party..ahh the lifestyles of the rich and famous:)I honestly don't believe this customer even thinks/knows what structuring means.
My point was, while we are investigating and filing SARs for normal behavior from this individual, the real "bad guys" are breaking the laws, but we are filing reports on someone's idiosyncrasies...But at any rate, SAR filed!!!
Thanks again for your input. I feel better now:)

I honestly don't believe this customer even thinks/knows what structuring means.

Then hand him the brochure.

. I wasn't suggesting that I wouldn't file, was just making an observation that the customer routinely draws $8,000 increments at least a few times a week.

Then he is routinely structuring.

If he was not he would be routinely going over $10,000.

Do not feel bad in the least. Why would the tailor not accept American Express Black? Or the catering hall a check? Even if he is not a "bad guy" who is to say the tailor is not hiring trafficked people to make his suit or the caterer not paying taxes to his employees catering the affair.

And to note I am completely against filing defensive SARs (I would say more than most on this thread)