Skip to content
BOL Conferences
Thread Options
#2076939 - 05/04/16 03:21 PM Subsequent reportable transaction after structure
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Accountholder transacted cash in what appeared to be a structured manner to avoid CTR filing, then a week later transacted cash over the reportable limit and a CTR was filed without incident. In your opinions, would the subsequent CTR reportable transaction mitigate the need to file a possible SAR for the alleged structured transactions?
_________________________
Go Packers

Return to Top
BSA/AML/CIP/OFAC Forum
#2076944 - 05/04/16 03:27 PM Re: Subsequent reportable transaction after structure Bec
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
if it was structured you file if not do not file.

A transaction for$ 9900. could be legit depending on the circumstances
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2076949 - 05/04/16 03:35 PM Re: Subsequent reportable transaction after structure Bec
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
It seems that it is more legitimized by the subsequent CTR reportable transaction. Would you agree with that opinion?
_________________________
Go Packers

Return to Top
#2076984 - 05/04/16 05:03 PM Re: Subsequent reportable transaction after structure Bec
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
Originally Posted By Bec
It seems that it is more legitimized by the subsequent CTR reportable transaction. Would you agree with that opinion?


That seems like a reasonable conclusion if the CTR was triggered by a single transaction. Otherwise, it may actually heighten the potential of structuring.
_________________________
CFE, CAMS

Return to Top
#2076996 - 05/04/16 05:33 PM Re: Subsequent reportable transaction after structure Pat Patriot Act
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
Originally Posted By Pat Patriot Act
Originally Posted By Bec
It seems that it is more legitimized by the subsequent CTR reportable transaction. Would you agree with that opinion?


That seems like a reasonable conclusion if the CTR was triggered by a single transaction. Otherwise, it may actually heighten the potential of structuring.


exactly
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2077047 - 05/04/16 07:37 PM Re: Subsequent reportable transaction after structure Bec
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
It was a single transaction, but the ones prior to were definitely suspicious for the appearance of structuring. I may not be able to overlook even considering the reportable transaction.
_________________________
Go Packers

Return to Top
#2077143 - 05/05/16 11:25 AM Re: Subsequent reportable transaction after structure Bec
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I met someone on the street and punched him in the nose. The next time we met I did not punch him in the nose. That does not mean I did not intend to do it the first time.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2077560 - 05/07/16 01:14 PM Re: Subsequent reportable transaction after structure Elwood P. Dowd
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
Thank you so much for the analogy, Ken. Can't wait to use it!!
_________________________
Nothing difficult is ever easy.

Return to Top

Moderator:  Andy_Z