Training module created by:  Title 31 Testing, LLC

SARs - Structuring

A person is STRUCTURING a transaction if they are acting alone or in conjunction with, or on behalf of other persons, conducts or attempts to conduct one or more transactions in currency, in any amount, at one or more financial institutes on one or more days, in any manner, for the purpose of evading the reporting requirements.

Examples:

• A guest, who is a big winner at the tables, enlists another guest to cash out some of the chips to avoid the filing of a CTR.
  

• A guest collects a number of slot tickets that are worth more than a known threshold for MTLs or CTRs and cashes out $2,000 at one window, then $2,500 at another window later in the day, followed by four more similar transactions at other windows, at various times throughout the day.
  

Red Lake Gaming Enterprises, Inc

Title 31 Training