Examples of Structured Transactions
The following scenarios are examples of structuring.
1. John has $15,000 in cash he obtained from selling his truck. John knows that if he deposits $15,000 in cash, his financial institution will be required to file a CTR. John instead deposits $7,500 in cash in the morning with one financial institution employee and comes back to the financial institution later in the day to another employee to deposit the remaining $7,500, hoping to evade the CTR reporting requirement.
2. Jane needs $18,000 in cash to pay for supplies for her wood-carving business. Jane cashes a $9,000 personal check at a financial institution on a Monday, then cashes another $9,000 personal check at the financial institution the following day. Jane cashed the checks separately and structured the transactions in an attempt to evade the CTR reporting requirement.
3. A married couple, John and Jane, sell a vehicle for $15,000 in cash. To evade the CTR reporting requirement, John and Jane structure their transactions using different accounts. John deposits $8,000 of that money into his and Jane’s joint account in the morning. Later that day, Jane deposits $1,500 into the joint account, and then $5,500 into her sister’s account, which is later transferred to John and Jane’s joint account.
4. Bob wants to place $24,000 cash he earned from his illegal activities into the financial system by using a wire transfer. Bob knows his financial institution will file a CTR if he purchases a wire with over $10,000 currency in one day. To evade the CTR reporting requirement, Bob wires the $24,000 by purchasing wires with currency in $6,000 increments over a short period of time, occasionally skipping days in an attempt to prevent the financial institution from filing a CTR.
If you have further questions, please contact FinCEN’s Regulatory Helpline at (800) 949-2732