BSA-AML Examiner School eBook

Internal Use Only

Example 1: SUSPECTED STRUCTURING - DEPOSITS WITHIN A WEEK 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.

Internal Use Only

Example 2: Suspicious Activity - customer, Jeffery Smith, opened checking account #33611440 on January 25, 2020 with an initial deposit of $34,300.00. The deposit consisted of $34,000.00 cash and a foreign check in the amount of $300.00. A CTR was filed for this deposit on February 6, 2020, with a Tracking ID of XXXXXXX and a BSA ID of XXXXXX. Our records indicate that Mr. Smith's date of birth is October 16, 2000, making him 19 years old. He is currently employed by Southern Lakes Trucking, LLC as a truck driver, and when the account was opened on January 25, 2020, our records indicate he was employed at Southern Lakes Farm, Southern Lakes, GA, as a farm hand. When our New Accounts Representative asked where he got this much cash from, he stated he had been saving up. On February 5, 2020 he made a cash deposit of $2,500.00. On February 12, 2020 he deposited $700 cash along with a foreign check drawn on Mark Berton Trucking, LLC, in the amount of $300.00, for a total deposit of $900.00. The check was drawn on XX Bank, routing number XXXXXXX, account number XXXXXX, check number 6500. The other transactions on the account are debit card transactions. Due to the fact that Mr. Smith deposited a large amount of cash when he opened the account and is at such a young age, this activity has been deemed suspicious, and a SAR is being filed. Supporting documentation can be located at the bank's main office.