Thread Starter: SARsSARsEvrywhre
Title: Re: Structuring non-taxable funds??
|
Let's assume there are several cash debit transactions and they all look like "obvious" typical structuring amounts.
Would you file for structuring of cash withdrawals if the source of funds was a personal injury settlement? Personal injury settlements are not taxable income, so what sense would it make that a customer is trying to avoid IRS finding out about the money?
Would you file for structuring of cash withdrawals if the source of funds was an SBA PPP? What sense would it make that a customer is trying to avoid the government finding out about the money that the government gave to them?
And if you would file for structuring on the SBA PPP proceeds, then would you consider structured proceeds to also be a sign that there was fraud in the application for the SBA PPP? In other words, would you report that as just structuring on your SAR, or structuring AND possible PPP fraud?
(Assume no other indication of fraud in PPP besides the fact that they structured out the proceeds.)
|
|
|
|
