Depositing by Piecemeal

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Question:

Our customer was going to deposit over $12,000, but changed his mind after he was told a CTR had to be filed. He said he would deposit $9,000 and come back the next day with the $3,000. He did not come back the next day. Are we required to monitor this account to see if he returns in the near future with the additional $3,000?

Answer:

No, what you are required to do is file a suspicious activity report because the customer intentionally reduced the amount of his deposit after learning that a CTR would be filed. That is structuring and must be reported.

First published on BankersOnline.com 11/22/10