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In Response To:
Thread Starter: ColoradoAML
Title: Re: Structuring non-taxable funds??

I think structuring is deceptively difficult. The exam manual gives some instruction to examiners that's consistent with what yours may have said:

"...two transactions slightly under the $10,000 threshold conducted days or weeks apart may not necessarily be structuring. For example, if a customer deposits $9,900 in currency on Monday and deposits $9,900 in currency on Wednesday, it should not be assumed that structuring has occurred. Instead, further review and research may be necessary to determine the nature of the transactions, prior account history, and other relevant customer information to assess whether the activity is suspicious. Even if structuring has not occurred, the bank should review the transactions for suspicious activity."

It's easy to agree with that statement in general, but in practice there are very few transactions that meet that pattern that we wouldn't file on.

There are plenty of reasons that a customer could deposit $6,000 on Monday and $6,000 on Wednesday, and we may not always know or be able to learn all the details of every single situation. Part of our process is to determine if it seems like it may be a one-time event and is coincidental. If that may be the case, our investigators have the ability to note it as such. If it happens again though, we go back and reconsider the original decision with the new information.