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World Runner
Captain
Posts: 3775
Joined: Mar 2002
11/26/2003 12:50 PM
If you are smurfing or structuring you can still get caught....Here's some stuff i've copied/ pasted from some training manuals that EVERY SINGLE EMPLOYEE of ours have taken.
Some of it is useless corporate garbage...well most of it is...but maybe SOMEONE will find it interesting. I see people's accounts flagged for structuring EVERY SINGLE DAY... Now I don't know what happens to it after that because I'm not really part of that process...i'm guess that the auditer just dismisses most everything. But if you're cashing $10,000+ worth of instruments in a period of a week from off-shore...it's probably been flagged...depending on the bank
A suspicious transaction is defined as a transaction conducted or attempted by,
at, or through a bank in the form of currency or other monetary form in which a
financial institution has reason to believe or suspect, or knows for a fact, that 1)
the transaction(s) involves funds from illegal activities or is intended or conducted
in order to hide or disguise funds/assets derived from illegal activities, 2) the
transaction is designed to evade any reporting requirements (i.e., the individual is
structuring the transaction(s), or 3) the transaction has no business or apparent
lawful purpose or is not the sort in which the customer would normally be
expected to engage. Transactions suspicious in nature, regardless of the
amount, should be reported to the appropriate person or department for further
review and reporting as applicable. This may include the CTR control officer
and/or Wells Fargo Investigations.
Financial institutions must provide specific information to federal agencies if
money laundering or unusual activity is suspected. This information includes the
individual's name, social security number, account number, and nature of the
suspicious activity.
Money laundering involves disguising profits from drug dealing and other illegal
activities such as tax evasion, bribery, extortion, embezzlement, mail or wire
fraud, insider trading, illegal gambling, prostitution, theft, and other crime.
Criminals conceal the source of their "dirty money" by trying to make it look
legitimate -- by "washing" it through financial institutions. Money laundering is
NOT limited to just currency transactions. Increasingly, it is being accomplished
by methods other than strictly using cash. Concern exists regarding the potential
to launder money via electronic banking as use of technology grows in popularity.
Laundering via loan proceeds and investment activities has also increased.
Financial institutions must report every currency transaction over $10,000 to
the IRS. Multiple cash transactions that, in aggregate, total more than $10,000
conducted by or for the same person on the same business day must be reported as
one transaction. A currency transaction is defined as the physical exchange of
currency at a teller line, through the ATM, or night deposit.
Financial institutions must report every currency transaction over $10,000 to
the IRS. Multiple cash transactions that, in aggregate, total more than $10,000
conducted by or for the same person on the same business day must be reported as
one transaction. A currency transaction is defined as the physical exchange of
currency at a teller line, through the ATM, or night deposit.
The financial institutions, and officers, directors, and all team members must
report any suspicious transaction relevant to a possible violation of federal
law or regulation.
The Suspicious Activity Report (SAR) form is to be used to report known or
suspected crimes, such as money laundering or structuring, to FinCEN.
Financial institution employees are prohibited from informing any individual(s)
involved in a suspicious transaction that the transaction has been or will be reported
to FinCEN.
IMPORTANT
Structuring is the most common method used by money launderers to evade BSA
reporting requirements. Structuring a transaction involves breaking large amounts
of currency into increments of $10,000 or less so that a CTR is not filed. Team
members must be careful not to help structure a transaction. More detail on
structuring is provided later in this training document.
Tellers and team members opening accounts or conducting transactions, should
be aware of the following:
•Customer is reluctant to provide proper identification
•Customer opens several accounts under one or more names and subsequently
deposits currency in amounts of $10,000 or less to each of the accounts
•Customer is reluctant to proceed with a transaction after being informed that a CTR
will be filed, or withholds information needed to complete the form
• Clients who claim to be in an extreme hurry to process transactions for which the
timing is described as “critical.”
•Customer frequently deposits or withdraws large amounts of currency for no
apparent business reason, or for a business that generally does not deal with large
amounts of cash
•Customer frequently purchases monetary instruments for currency in amounts of
$10,000 or less
•Customer exchanges large amounts of currency from small to large denomination bills
• Customer deposits currency that has a peculiar or unpleasant odor indicating storage in
unusual locations, including a safe deposit box.
•Several customers enter the bank simultaneously and each conducts a transaction
in amounts of $10,000 or less with different tellers or bankers
• Customer requests wire transactions that do not seem reasonable.
•Customer frequently visits the safe deposit box area, possibly indicating the
safekeeping of large amounts of currency or illegal substances. A large cash
transaction may be conducted prior to or after visiting the safe deposit box.
•Customer discusses intent to avoid BSA reporting requirements or makes threats to
a team member to deter the filing of a CTR
•Customer requests to be included on the financial institution's exemption list to be
exempt from reporting of large cash transactions
•Customer frequently deposits funds (e.g. currency, incoming wire transfers,
monetary instruments) and almost immediately wire transfers the funds to another
city or country, and that activity is inconsistent with the customer's stated business
•Customer receives wire transfers and immediately purchases monetary instruments
for payment to another party
• Customer deposits foods stamps in unusually high amount or amounts inconsistent
with their business
• Customer makes a deposit containing a large amount of domestic and/or foreign
traveler’s checks. The instruments may contain illegible payees and endorsers’
signatures and the checks may be sequentially numbered
Wire transfer or team members involved in wires, should be aware of the following:
•Customer increases wire transfer activity, or makes international wire transfers,
which is inconsistent with previous wire activity.
• Clients who claim to be in an extreme hurry to execute documents or process
transactions for which the timing is described as “critical.”
•Customer frequently deposits funds (e.g. currency, incoming wire transfers, ACH
transfers, monetary instruments) and almost immediately transfers the funds to
another city or country, and that activity is inconsistent with the customer's stated
business or previous activity.
•Customer uses wire transfers to move large amounts of currency to drug-haven
countries, to countries with few or no bank secrecy laws, or to an off-shore bank.
•Non-accountholder requests to send or receive wire transfers involving currency
near the $10,000 limit, or involving numerous monetary instruments. (Note:
Typically transfers over $3,000 in cash are not accepted, unless given proper
approval by an officer.)
•Non-accountholder receives incoming wire transfers with instructions to the financial
institution to "Pay Upon Proper Identification" or to convert the funds to cashier's
checks and mail to a non-account holder.
• Large wire or ACH transfers (possibly more than one per day) received into an
account for a customer who structures cash withdrawals as soon as the funds are
received.
EXAMPLES OF POTENTIAL STRUCTURING
#1 - A customer makes multiple currency deposits in amounts less than $10,000, but
totaling more than $10,000 over several consecutive or near consecutive days, via tellers,
ATM or night depository at the same bank, different branches of the same bank, or at
different banks.
#2 - A customer deposits $8,000 in currency on Monday, Tuesday, Wednesday, and
Thursday. On Friday, the customer requests $30,000 be wire transferred out of the
country.