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#2245015 - 11/03/20 04:38 PM Structuring
complofcr Offline
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I have read the definition of structuring. However, what would it be called if the customer only conducts 1 transaction that is less than $10,000. For instance, the customer cashed a check for $9,990. I'm pretty certain the customer cashed the check for this amount to keep it less than $10,000 but is it considered structuring since it was only 1 transaction?

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#2245016 - 11/03/20 04:40 PM Re: Structuring complofcr
rlcarey Offline
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It is awfully hard to structure one transaction. You would need a lot more information to make that determination. If I sold a car for $9,999 and cashed the check, that would not be structuring.
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#2245018 - 11/03/20 04:48 PM Re: Structuring complofcr
Oursisnottoreasonwhy Offline
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It probably doesn't qualify as structuring, but you could still file a SAR for transaction out of normal pattern.

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#2245022 - 11/03/20 04:58 PM Re: Structuring rlcarey
complofcr Offline
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Thanks! That was my thinking also.

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#2245026 - 11/03/20 05:33 PM Re: Structuring Oursisnottoreasonwhy
edAudit Offline
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Originally Posted by Oursisnottoreasonwhy
It probably doesn't qualify as structuring, but you could still file a SAR for transaction out of normal pattern.



Just wondering. I own a business and I get one contract that is $9500 vs. $7000 as a normal fee you would file a SAR?

There is probably many third parties here that would have SARs filed on them for this logic.

Investigation is the key to file or not to file
Last edited by edAudit; 11/03/20 05:34 PM.
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#2245046 - 11/03/20 07:01 PM Re: Structuring complofcr
Skittles Online
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While I agree with everyone - the only thing I want to add is if the customer lowered the amount of cash he wanted to avoid filing the CTR - then you would more than likely file for structuring.
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#2245052 - 11/03/20 08:09 PM Re: Structuring complofcr
ACBbank Offline
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I wouldn't file on one (1) transaction unless there is a situation like Skittles referenced. IO structuring needs to be a pattern. Do you really want to be filing SARs on every transaction below $10,000?
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#2245057 - 11/03/20 08:35 PM Re: Structuring complofcr
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted by complofcr
However, what would it be called if the customer only conducts 1 transaction that is less than $10,000.


What would it be called? it would be called a deposit.
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#2245063 - 11/03/20 09:08 PM Re: Structuring complofcr
BrianC Offline
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There is the box "Alters transaction to avoid CTR" but that only applies to the customer who wanted to withdraw more than $10,000 and then decides to withdraw $9,990.
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#2245064 - 11/03/20 09:41 PM Re: Structuring HappyGilmore
John Burnett Offline
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Originally Posted by HappyGilmore
Originally Posted by complofcr
However, what would it be called if the customer only conducts 1 transaction that is less than $10,000.


What would it be called? it would be called a deposit.

Or withdrawal.
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#2245402 - 11/10/20 09:25 PM Re: Structuring BrianC
John Burnett Offline
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Originally Posted by BrianC
There is the box "Alters transaction to avoid CTR" but that only applies to the customer who wanted to withdraw more than $10,000 and then decides to withdraw $9,990.


Or deposit.
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#2245494 - 11/13/20 05:44 PM Re: Structuring complofcr
IronP2717 Offline
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Agree w/Randy. A single $9990 transaction alone would be hard to say it's structuring.
However, i've had customers say, "what's that cash limit?" give them the brochure. They review. Then say, " ok. give me $9500." Or They've told the teller they instruct their customers/clients to write checks below 10k.

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#2245498 - 11/13/20 06:28 PM Re: Structuring complofcr
ColoradoAML Offline
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I agree with IronP's point.

Generally BOL threads addressing whether or not something is suspicious give the advice to investigate. While I agree that a customer cannot structure if they don't desire to transact over the reporting limit, just because a transaction or series of transactions that you identify is below the limit doesn't mean they weren't structured.

Rarely, based on our knowledge of the customer, their relationship to us, their relationships with other banks, the source of their income and wealth, etc., there are many circumstances that may lead us to believe that a $9,999 transaction was structured.

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#2245528 - 11/14/20 12:07 AM Re: Structuring complofcr
Adam Witmer Offline
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The other thing to consider when looking into a $9,999 transaction is to see if there is some sort of limit that forced this amount? For example, while it wasn't a cash transaction, I once tried making a $11,000 principle reduction on my mortgage and found out that the system limited online payments/principle reductions to $9,999. While this wasn't a cash deposit, I've had enough issues with this mortgage servicer that I thought to myself "Great. Some idiot is going to see my consecutive day payments of $9,999 and $1,001 and think I'm structuring an $11,000 transaction because they don't realize they have a system limit."

So, I just left it at a $9,999 payment and didn't add the $1,001 in hopes that they wouldn't worry about a single transaction. wink
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#2245762 - 11/20/20 09:34 PM Re: Structuring complofcr
Bec Offline
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You could also say its isolated.
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#2246029 - 12/01/20 07:48 PM Re: Structuring complofcr
HappyGilmore Offline
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Pulling people out of the ditc...
Quote
However, i've had customers say, "what's that cash limit?" give them the brochure. They review. Then say, " ok. give me $9500."


but this still does not define structuring,,,unless they then come back and withdraw $500.01 or greater in short period of time
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#2246032 - 12/01/20 08:21 PM Re: Structuring complofcr
BrianC Offline
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Illinois
If the bank concludes that the customer's original intent was to withdraw more than $10,000 and they don't there is still the box on the SAR for "Alters transaction to avoid reporting" which I might use in connection with "Suspicious inquiry regarding reporting thresholds."
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