I would be hesitant to accuse any customer of structuring, implicitly or not. It's been my experience that if you provide the customer with the pamphlet, most will stop and the few that continue their pattern can be exited with minimal complaints from the BU.
Last edited by ACBbank; 10/23/14 03:43 PM. Reason: Added more detail
BTW, make sure to reference in your SAR filing that you've provided the customer with the FinCEN pamphlet. Law enforcement loves that.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu