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#2264883 - 01/19/22 05:23 PM SAR - Structuring, what amount to file?
ComplianceNerd Offline
Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
Looking for simple guidance as I have forgotten over the years.

Customer makes a deposit for $12,000, $9,900 is cash. Would I file the SAR for $9,900 or $12,000.

Any reference to FinCEN guidance/Reg would be appreciated too if you're familiar with it.

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#2264884 - 01/19/22 05:28 PM Re: SAR - Structuring, what amount to file? ComplianceNerd
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,428
Illinois
You won't find any written guidance. You report the dollar amount of the transaction(s) your institution considers suspicious. Do you consider the $2,100 in checks suspicious? If yes, report $12,000. If no, report $9,900.

Of course, if you consider the $2,100 in checks suspicious, you'll need a check box besides structuring to avoid CTR requirements since the check deposit wasn't structured.
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