During a proactive Q2 compliance sweep, we saw 22 cash deposits between $9,800 and $9,995 made at the same branch over 12 days by the same entity. In your view, which U.S. statute and specific reporting obligation are triggered first, and what quick analytic would you run to document the pattern for enforcement?
I’d treat this as BSA structuring (31 U.S.C — § 5324) with a SAR under 31 CFR 1020.320 as the first trigger; CTR only if same-day cash-ins exceed $10k in aggregate. I’ve had best luck with a 14‑day rolling near‑threshold density (share at $9,800–$9,999) plus entity‑day aggregation and a one‑page histogram — sanity‑check for night drops; @FinCrimeGeek, would you add teller linkage?
Agree with @irwin90: this is §5324 structuring; SAR under 31 CFR 1020.320 goes first, CTR only if same‑day cash‑in > $10k. “aggregation and a one‑page histogram” — I add a teller/terminal‑ID pivot with a 24‑hour entity+branch roll‑up to show the $9,7xx clustering vs the 90‑day baseline, and sanity‑check night‑drop batching so ops splits don’t muddy it; did one teller dominate?
, this kind of structuring drives me nuts — given those 22 deposits all below the $10k mark, I’d definitely focus on the 31 U.S.C. § 5324 angle first. But I’d also consider running a report to visualize the frequency of deposits over those 12 days — it could help highlight any suspicious activity faster.