Another financial institution in the area was advised by their examiner they should have a reporting mechanism in place to identify structured transactions. This would be for SAR reporting. The examiner would not provide any direction/suggestion as to the daily dollar threshold or the period of time that should be considered.
Two questions: has anyone else encountered this? does anyone currently review transactions over period of time to determine if structured transactions would be subject to SAR reporting.

We review a monthly report, which shows all cash transaction in amounts over $ 500, which aggregate at least $ 5,000 in a month. If a customer goes to multiple branches on the same day, or several days during the month, and the activity exceeds $ 10,000, we file a SAR. We were reviewing all transactions aggregating $ 3,000 and over, but our report was huge, so the Examiners recommended that we raise the threshold to $ 5,000. Not often the Examiners tell you that you are doing TOO much...

We use several reports to identify structuring. One key report report identifies customers who exceed $10,000 in cash in or out over a rolling 7 day period. We do have another report that shows all cash that we can sort various ways to identify structuring. We sometimes find structuring across multiple accounts in that manner.

Have you looked at software to help you sort your data? AML software can pull the data from your core and help you track not only cash structuring for deposits, but for withdraws as well. Our system even aggregates if a customer cashes a transit check at the teller line even though the transaction doesn't affect their account. It also aggregates cash puchases of monetary insturments. Great stuff.