BSA/AML Examiner School eBook

Internal Use Only

SAR Quality

Internal Use Only

Example 1: SUSPECTED STRUCTURING - DEPOSITS WITHIN AWEEK OF EACH OTHER IN AMOUNTS OF $9,000.00 Suspected Structuring – On April 20, 2019, when reviewing daily reports for the Bank Secrecy Act, there was a new savings account that had been opened in the name of Grant Thomas #35456 with a cash deposit in the amount of $9,000.00. A week later on April 27, 2019, there was another cash deposit to the same savings account of Grant Thomas #35456, in the amount of $9,000.00. The account was flagged for potential structuring, with a review for the next week ending May 8, 2019, showing no additional cash deposits. Due to the initial cash deposit being in an amount right under the CTR threshold, with an additional cash deposit the very next week right under the CTR threshold, structuring was suspected, and this SAR was filed. Supporting documentation is located at the bank's main office.