In the United States, deliberately structuring cash transactions to avoid a currency transaction report is a federal offence in itself, even if the money is legitimate. Many other jurisdictions treat it as a strong red flag. Monitoring rules look for repeated deposits just below a threshold, or the same cash split across branches, accounts or people.
Example
A customer deposits USD 9,000 in cash on three consecutive days at different branches.
Where it appears in the exams
This topic is relevant for CAMS, CFCS.
Related terms
- Placement: Placement is the first stage of money laundering, in which criminal cash or other proceeds are put into the financial system or converted into other assets.
- Transaction monitoring: Transaction monitoring is the ongoing review of customer transactions to spot activity that is unusual or inconsistent with what is known about the customer, so that it can be investigated and, if needed, reported.
- Suspicious activity report (SAR / STR): A suspicious activity report, also called a suspicious transaction report, is a confidential report that a regulated firm files with the national financial intelligence unit when it suspects money laundering, terrorist financing or another crime.
Source: US Bank Secrecy Act (31 USC 5324) and FinCEN guidance. Independent explanation for study purposes, not legal advice.