Gearhead Jim
Full time employment: Posting here.
^^^^^
Was it the US or the receiving country that wanted your info?
Was it the US or the receiving country that wanted your info?
Is Moving Large Amounts of Cash a Red Flag?
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HenryD
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Banking regulations in the receiving country (Costa Rica), although they are squarely within the influence of and totally dominated by the United States, of course. The banking there is definitely more traditional in nature but I've been led to understand these requirements are driven mostly by the need to report to US entities(?) Apparently, there was a lot of money laundering through there in the 1980s.
NXR7
Recycles dryer sheets
A CTR, cash transaction report, is exactly that, cash. A CD is not cash. Businesses that deal with a lot of cash get a lot of CTRs filed.
SAR's, suspicious activity reports, can be filed for any reason and I stress "any" and there is no minimum transaction amount.
Structured transactions are always a red flag and a SAR. A structured transaction is where you make multiple small transactions (even separated by many days or weeks) to try and stay below the regulatory thresholds for reporting. Yes, you will get caught. Maybe not immediately but you will get caught.
When I was working in banking several years ago the feds asked for financial institutions to voluntarily file CTRs for amounts less than $10,000. I think it was $5,000. Then they asked again for CTRs for $3,000 voluntarily. (I don't know if this was a regional thing or not.)
I don't know of any that did; we sure did not. Our compliance people were aghast at the request because it could kick back on us. The feds cannot be sued plus they simply "asked". We would have been the ones taking on all of the liability if one of our customers got government attention because we filed a CTR for a lower amount.
SARs, we filed those a lot. We even filed them for fraud attempts by non-customers.
A not so funny story: Our internal controls picked up some oddities and the investigation nailed a branch manager and the assistant manager. The manager's spouse owned a construction or remodeling business and apparently was getting paid in cash. A lot of cash.
Somehow the branch manager enlisted the help of the assistant branch manager in structuring the cash transactions to avoid CTRs and thus potentially alerting the IRS to undeclared income. Dual controls? Right out the window when collusion is involved. But it's pretty tough to hide from the computers.
Yeah, that is a crime and both were convicted and banned from ever working in banking again. When it became clear what was going on the bank immediately transferred all new personnel to that branch and immediately scattered every employee of that branch to other branches because no one knew who was colluding with who. Turned out it was just those two.
Here's where it gets funny. It was all hush-hush but what many people did not know was that, at the time, when people were banned from banking our federal regulator published a PDF of who did what. I knew it but had no idea most people did not.
We were in a controls meeting years later and I brought up collusion as a possibility of a control change. I was told by a very senior manager that we had never had a collusion problem and we screened our people carefully.
Challenge accepted.
I brought up that example and named the names. I could not understand how that senior manager had no idea.
Turned out he did but he had no idea I knew. He knew of the incident but was never told the names yet somehow a lowly employee knew everything.
A week later my manager said we needed to go chat with HR. Because that's always fun. The HR SVP asked me how I knew all of those details and it was very clear from the tone and her wording that they thought I had hacked into confidential files.
I actually replied "Seriously? You're kidding right?"
No, they were not kidding.
I then showed them where on the Internet our federal regulator published all of those details for the entire world to read.
SMH.
SAR's, suspicious activity reports, can be filed for any reason and I stress "any" and there is no minimum transaction amount.
Structured transactions are always a red flag and a SAR. A structured transaction is where you make multiple small transactions (even separated by many days or weeks) to try and stay below the regulatory thresholds for reporting. Yes, you will get caught. Maybe not immediately but you will get caught.
When I was working in banking several years ago the feds asked for financial institutions to voluntarily file CTRs for amounts less than $10,000. I think it was $5,000. Then they asked again for CTRs for $3,000 voluntarily. (I don't know if this was a regional thing or not.)
I don't know of any that did; we sure did not. Our compliance people were aghast at the request because it could kick back on us. The feds cannot be sued plus they simply "asked". We would have been the ones taking on all of the liability if one of our customers got government attention because we filed a CTR for a lower amount.
SARs, we filed those a lot. We even filed them for fraud attempts by non-customers.
A not so funny story: Our internal controls picked up some oddities and the investigation nailed a branch manager and the assistant manager. The manager's spouse owned a construction or remodeling business and apparently was getting paid in cash. A lot of cash.
Somehow the branch manager enlisted the help of the assistant branch manager in structuring the cash transactions to avoid CTRs and thus potentially alerting the IRS to undeclared income. Dual controls? Right out the window when collusion is involved. But it's pretty tough to hide from the computers.
Yeah, that is a crime and both were convicted and banned from ever working in banking again. When it became clear what was going on the bank immediately transferred all new personnel to that branch and immediately scattered every employee of that branch to other branches because no one knew who was colluding with who. Turned out it was just those two.
Here's where it gets funny. It was all hush-hush but what many people did not know was that, at the time, when people were banned from banking our federal regulator published a PDF of who did what. I knew it but had no idea most people did not.
We were in a controls meeting years later and I brought up collusion as a possibility of a control change. I was told by a very senior manager that we had never had a collusion problem and we screened our people carefully.
Challenge accepted.
I brought up that example and named the names. I could not understand how that senior manager had no idea.
Turned out he did but he had no idea I knew. He knew of the incident but was never told the names yet somehow a lowly employee knew everything.
A week later my manager said we needed to go chat with HR. Because that's always fun. The HR SVP asked me how I knew all of those details and it was very clear from the tone and her wording that they thought I had hacked into confidential files.
I actually replied "Seriously? You're kidding right?"
No, they were not kidding.
I then showed them where on the Internet our federal regulator published all of those details for the entire world to read.
SMH.
Last edited:
Valid not Invalid
Dryer sheet wannabe
Very informative post NXR7 and thanks for highlighting the “cash” part of the transaction. Title 31, Section 5324 of the US Code covers structuring and basically trying to evade the reporting requirements. The G generally won’t charge that code, but uses the info to find, follow, and ultimately charge the underlying crime.
JoeWras
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This is a good post.
mickeyd
Give me a museum and I'll fill it. (Picasso) Give me a forum ...
Unless it's 10 figures, sleep tight.
JoeWras
Give me a museum and I'll fill it. (Picasso) Give me a forum ...
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Greeks have 6 words for love. English has one.
English has an enormous variety of words for "money," yet we seem to default to "cash."
It is a problem in the context of this thread. There's a huge difference between paying "cash" for a house, meaning no loan, than laundering your drug "cash" (actual bills) to pay for the house.
Rianne: I am not criticizing your post. I use the same wording. I'm just a bit perplexed how "cash" has come to mean a variety of things and it causes confusion.
English has an enormous variety of words for "money," yet we seem to default to "cash."
It is a problem in the context of this thread. There's a huge difference between paying "cash" for a house, meaning no loan, than laundering your drug "cash" (actual bills) to pay for the house.
Rianne: I am not criticizing your post. I use the same wording. I'm just a bit perplexed how "cash" has come to mean a variety of things and it causes confusion.
FloridaJim57
Recycles dryer sheets
As long as you can account for where the money came from, then you have nothing to worry about. I am assuming you are discussing domestic transfers of bank to bank or bank to investment houses, etc.
