Training module created by:  Title 31 Testing, LLC

SARs - Layering and "Smurfing"

The following are also examples of suspicious transactions.

• Layering - The launderer engages in a series of conversions or movements of funds to distance them from their source.
  

• Smurfing - also know as structuring.  The guest reduces the amount of their transaction to circumvent reporting. 
  

We will now review the SAR material with sample scenarios as they relate to suspicious activities.  When you are ready, hit NEXT.  Hit BACK to review the material again before proceeding.

Red Lake Gaming Enterprises, Inc

Title 31 Training