On discovering employees had unintentionally provided assistance to customers who were structuring transactions, an anti-money laundering specialist…

Structuring is the practice of breaking down large amounts of cash into smaller transactions to avoid

triggering currency transaction reports (CTRs) or suspicious activity reports (SARs) by financial

institutions. CTRs are required for cash deposits or withdrawals of more than $10,000 in the United

States, and SARs are filed when there is a reasonable suspicion of money laundering or other illicit

activity. By making multiple deposits of less than $10,000 at different tellers, the owner of the retail

store is attempting to evade the reporting requirements and conceal the source or destination of the

funds. This is a common technique used by money launderers in the placement stage of the money

laundering process, when they try to introduce illegal proceeds into the financialsystem. Structuring

is illegal under the Bank Secrecy Act and can result in civil and criminal penalties.

6: CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and

Methods, page 43

1: Structuring Cash Deposits, Withdrawals, & Transactions Risk, Golding & Golding

2: Structuring - Wikipedia