The USA Patriot Act requires financial institutions to look for activity that may be considered structuring. Structuring transactions involves the deposit or withdrawal of funds purposefully in a pattern in order to avoid the reporting threshold of ten thousand dollars.
At the local Jacksonville ACFE annual fraud seminar on August 20, 2010, an agent from the U.S. Immigration and Customs Enforcement supplied a list of potential red flag indicators of structuring:
• Frequent transactions or purchase of negotiable instruments under $10,000 in over to avoid filing a Currency Transaction Report (CTR)
• Customer making cash deposits under $10,000 at multiple locations or cash deposits made to one account at the same location by multiple individuals
• Customer depositing less than $10,000 after begin told of CTR reporting requirement
• Splitting large currency transactions among several accounts
If you suspect structuring always follow your internal policy to properly report this suspicious activity.
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