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Avoiding Filing CTR- Deposit on 2 Diff Days

I overheard an employee recommending to a customer to deposit part of a deposit one day and the rest of the money the next day, therefore avoiding the filing of a CTR. What action would need to be taken on this employee? I need to make sure that all the bases are covered and all the reports needing filed are filed.

Answer by Ken Golliher: Without knowing what your role is, it's difficult to say. "Assisting in structuring" is a crime. Use whatever your bank's mechanism for reporting suspicious activity might be. It should be put in the pile for SAR consideration.


Answer by Richard Insley: This is a very serious problem. The subject employee appears to have committed a crime and you witnessed it. If the customer follows the "suggestion" s/he, too, will commit a crime. If you have to post a question in a public discussion forum in order to know what to do, your bank's BSA/AML program is deficient--and that may expose the bank to the same criminal charges as the subject employee. An important part of such a policy is a statement of the steps all employees must take when they become aware of structuring. Equally important (and apparently lacking) is effective staff training re the policy. If your bank does have a satisfactory policy for handling cases involving structuring and you neither(a) follow it, nor (b) report the suspicious activity on your own, YOU may also become involved in the crime.

First published on 7/15/13

First published on 07/15/2013

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