Dr. Michael Recce, Chief Scientist at Fortent, the risk and compliance technology and information company, explains: âStructuring is a favorite method used by money launderers to attempt to avoid detection.
âDue to the Bank Secrecy Act and the USA PATRIOT Act regulations, banks are required to report customer transactions of $10,000 or more to federal authorities. So in order to get around these requirements, an individual could âstructureâ or divide payments into a set of transactions where each individual transaction is below this $10,000 threshold. This maneuver increases the chances that the individual would fly under the radar of banksâ compliance departments.
âDivided transactions raise suspicion levels, and banks have systems in place to detect just this sort of criminal behavior.â
Common signs of structuring, says Dr. Recce, include:
1. Movement of cash in multiple transactions under $10,000 â âObviously, not every transaction of under $10,000 is suspect, but if banks see a pattern of cash movement to the same account when it doesnât seem to make sense, this raises red flags.â
2. Attempts to take the senderâs name off wire transfers â âIf you have nothing to hide, why would you try to conceal your transactions?â
3. Large cash deposits made to ATMs â âMost people deposit checks, not cash, into ATMs, so banksâ systems tend to raise red flags for these types of transactions.â
âTo detect structuring,â says Dr. Recce, âanti-money laundering systems, such as Fortentâs, look for situations in which multiple transactions of slightly under $10,000 are performed within short periods of time, possibly at multiple branches or locations of a bank.â