Micro-structuring

The definition of structuring encompasses transactions that attempt to evade the Currency Transaction Reporting (“CTR”) requirement of deposits or withdrawals of cash/cash instruments over $10,000. This may occur as a single transaction approaching $10k or several smaller transactions in different locations of the same institution on the same day or within a short period of […]

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Smurfing

As the Bank Secrecy Act evolved, requiring banks to file Currency Transaction Reports on cash and cash items in or out greater than $10,000, the criminal element was quick to develop an alternative approach to getting money into the financial system, covering the Placement phase of Money Laundering. Keeping in mind that the original crime […]

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