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#1909333 - 03/27/14 06:13 PM Re: Structuring John Burnett
raitchjay Offline
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Joined: Oct 2009
Posts: 9,144
OK
Originally Posted By: John Burnett
The press is notorious for misinformation on money laundering and related cases. My major "beef" about some of these cases is that it's likely that SARs have been filed without any attempt to understand what the customer is actually doing -- in other words, without the conversation that Ken alluded to. These are "defensive filings" of the worst kind, because they can lead to cases like some of the horror stories mentioned above.


John.....your post here is basically what i was trying to determine with my questions, since again, i'm not a BSA officer. The "defensive filings" as you call them are what i was imagining and if i was the person who had a SAR filed for this reason, and came to find out about it, i don't think i'd be very happy.
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#1909438 - 03/27/14 07:50 PM Re: Structuring Retread
McGruff Offline
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McGruff
Joined: Feb 2004
Posts: 262
Texas
I heard a law enforcement officer explain to a teller that he was depsoiting a $20,000 check and he knew we had to file a CTR. He was utterly shocked to find out it only applied to cash.

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#1909449 - 03/27/14 08:10 PM Re: Structuring Retread
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
I have customers who occasionally deposit $10,000 cash and they aren't structuring, because they believe a CTR is being filed on that amount.

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#1909572 - 03/28/14 01:56 PM Re: Structuring Retread
NU Rhules Offline
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NU Rhules
Joined: Mar 2011
Posts: 479
SE, Nebraska
How come nobody has mentioned using this? I'd like your thoughts on about it's use in situations described above where the customer may or may not know what they are doing and from the bank's perspective appears to be structuring. And getting information out of them proves difficult for lack of interview skills at the teller level. http://www.fincen.gov/whatsnew/html/20090224.html

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#1909599 - 03/28/14 02:16 PM Re: Structuring NU Rhules
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Well, this thread meandered some, no question. If you search this forum for the word "pamphlet" you will find several prior discussions.
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