Besides distributing the brochure, Facts You Should Know, I have the account officer interview the customer regarding the activity as a marketing discussion to determine if the customer needs cash management products. To this day, I am still surprised how many accountants and attorneys "advise" their clients to stay under the reporting threshold when depositing/withdrawing cash. After a brief conversation with the customer(s), they are actually relieved to deposit/withdraw large amounts of cash & file a CTR. The customer's that continue to structure after being interviewed are either given the goodbye notice or an anaysis of the business receipts can justify the cash activity as being normal. Of course all this is documented in our legal files and we have had no issues with internal auditors or the regulators regarding our due diligence process.
These are just my own opinions...my body is here but my mind has already teed off...FORE!