Training module created by:  Title 31 Testing, LLC

SARs - Avoiding CTR Reporting

Any manner including but not limited to, the breaking down of a single sum of currency exceeding $10,000 into smaller sums, including sums at or below $10,000.  The transaction or transactions need not exceed the $10,000 reporting threshold at any casino on any single Gaming Day in order to constitute structuring a transaction.

The transaction must be e-filed to the Internal Revenue Service by the 30th day after the transaction on a Suspicious Activity Report.

• Many of the individuals that seek to avoid CTRs are aware of the $10,000 threshold.  Some of those individuals will develop elaborate plans to avoid reporting on CTRs and SARs.
  

Examples:

• A customer asks you to advise her when she is about to exceed $10,000 or an amount close to $10,000.
  

• A customer asks you what time your Gaming Day starts.
  

Red Lake Gaming Enterprises, Inc

Title 31 Training