If we have a customer ask a teller, "What amount can I deposit to avoid the bank from reporting the cash deposit?" - what can that teller say? Can we just tell the customer that the bank is required by law to file a report on cash transations greater than $10,000 and say nothing more? I want to make sure we aren't facilitating or instructing the customer on structuring.
I know we need to file a SAR - especially since the customer proceeded to make two cash deposits of slightly less than $10,000 over the next two days.
One thing this has done is prompted us to provide each branch with a bunch of copies of FinCEN's CTR brochure to hand out in the future when questioned.