# The hard part of money laundering **URL:** \ **Category:** Factual Questions\ **Created:** [June 19, 2021, 11:10pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654 "2021-06-19T23:10:00Z")\ **Posts on this page:** 20\ **Page:** 18
**Author:** ![k9bfriender](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/k9bfriender/32/3283_2.png) [@k9bfriender](https://boards.straightdope.com/u/k9bfriender)\ **Post date:** [July 9, 2021, 5:01pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/342 "2021-07-09T17:01:22Z")
I find that to be a bit more confusing now. Is currency only cash, or is currency any form of money? According to: > **[Currency Transaction Report (CTR): Use in Banking and Triggers](https://www.investopedia.com/terms/c/ctr.asp)** > > A currency transaction report (CTR) is used in the banking industry to monitor and report cases of potential money laundering. > [@](#): > > In order to prevent financial crimes, CTRs require institutions to verify the identity and Social Security Numbers of anyone attempting a large transaction, whether or not that person has an account with the institution. > [@](#): > > When a customer initiates a transaction involving more than $10,000, most bank software will automatically create a CTR electronically and fill in tax and other customer information. Doesn’t sound like its limited to cash. Wonder if someone more personally knowledgeable, like @DrDeth can weigh in on how to interpret that. > [@md-2000](#): > > People do large electronic/cheque transactions all the time. Businesses, more so. People do occasionally. My personal finances it’s only really been once. As far as businesses, large publicly traded businesses are exempt, and us smaller ones probably don’t run into that limit all that often. Compared to all the other paperwork involved in applying for and consolidating loans, a CTR is pretty minor. I do wonder, when I wrote my contractor out a check for around 20k, did he have a CTR filled out when he cashed it? ---
**Author:** ![DrDeth](https://avatars.discourse-cdn.com/v4/letter/d/b487fb/32.png) [@DrDeth](https://boards.straightdope.com/u/DrDeth)\ **Post date:** [July 9, 2021, 5:08pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/343 "2021-07-09T17:08:21Z")
> [@k9bfriender](#): > > Doesn’t sound like its limited to cash. Wonder if someone more personally knowledgeable, like @DrDeth can weigh in on how to interpret that. Currency for the purposes of a CTR is _cash._ _Federal law requires financial institutions to report **currency** ( **cash** or coin) transactions over $10,000 conducted by, or on behalf of, one person, as well as multiple **currency** transactions that aggregate to be over $10,000 in a single day. These transactions are reported on **Currency** Transaction Reports (CTRs)._ [https://www.fincen.gov/sites/default/files/shared/CTRPamphlet.pdf](https://www.fincen.gov/sites/default/files/shared/CTRPamphlet.pdf) [https://www.fdic.gov/news/financial-institution-letters/2021/fil21012c.pdfA](https://www.fdic.gov/news/financial-institution-letters/2021/fil21012c.pdfA) bank must electronically file a Currency Transaction Report\* ( _CTR_ ) for … 1 31 CFR 1010.100(m) defines _currency_ as coin and paper \*money. > [@k9bfriender](#): > > I do wonder, when I wrote my contractor out a check for around 20k, did he have a CTR filled out when he cashed it? If he deposited it- NO. If he actually cashed it, took $20k in cash out- then yes. When I consulted for a large brokerage company, wire & electronic/cheque transactions in the millions were common. Of course, a SAR could be filed if they look suspicious. ---
**Author:** ![k9bfriender](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/k9bfriender/32/3283_2.png) [@k9bfriender](https://boards.straightdope.com/u/k9bfriender)\ **Post date:** [July 9, 2021, 5:15pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/344 "2021-07-09T17:15:39Z")
Cool thanks. That’s what I was thinking, but I found that Investopedia page pretty ambiguous. > [@DrDeth](#): > > Of course, a SAR could be filed if they look suspicious. I do sometimes look a bit suspicious. 🕶 ---
**Author:** ![Hatchie](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/hatchie/32/3983_2.png) [@Hatchie](https://boards.straightdope.com/u/Hatchie)\ **Post date:** [July 9, 2021, 6:18pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/345 "2021-07-09T18:18:03Z")
The Scrooge McDuck fortune (does anyone even know where it comes from?) is all cash, in the form of coins that McDuck frequently dives into (“guinea dipping”). In this case, the money is actually laundering its owner, though I’d keep a safe distance myself. ---
**Author:** ![Pleonast](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/pleonast/32/1183_2.png) [@Pleonast](https://boards.straightdope.com/u/Pleonast)\ **Post date:** [July 9, 2021, 7:21pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/346 "2021-07-09T19:21:00Z")
> [@md-2000](#): > > Let’s be clear - there are two types of reports, if I understand this thread correctly: > > CTR: > > > A currency transaction report (CTR) is a bank form used in the United States to help prevent [money laundering](https://www.investopedia.com/terms/m/moneylaundering.asp). This form must be filled out by a bank representative whenever a customer attempts a currency transaction of more than $10,000. It is part of the banking industry’s [anti-money laundering] (AML) responsibilities. > > In order to prevent financial crimes, CTRs require institutions to verify the identity and Social Security Numbers of anyone attempting a large transaction, whether or not that person has an account with the institution. > > CTR - no big deal if the cash is legitimate. Probably happens a lot. Dumb question, and I apologize if it’s already been answered: can a bank customer demand that the bank fill out a CTR? Or may the bank refuse? For example, let’s say my legitimate business is going to have a spike in demand (it’s county fair week) and my cash deposits jump up to $9000 from a much lower usual amount. When I go to the bank on Monday, I tell the bank I want a CTR. Can the bank refuse? When I go to the bank Tuesday, I ask for another CTR. Can they still refuse? Etc, for each following day. What are my rights here? Can I self-report my deposits without the bank’s consent? Can I demand the bank report all my deposits, no matter how small? ---
**Author:** ![k9bfriender](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/k9bfriender/32/3283_2.png) [@k9bfriender](https://boards.straightdope.com/u/k9bfriender)\ **Post date:** [July 9, 2021, 7:22pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/347 "2021-07-09T19:22:54Z")
Or is it illegal to “structure” your deposits to make sure that they are over $10,000 and generate a report? ---
**Author:** ![doreen](https://avatars.discourse-cdn.com/v4/letter/d/858c86/32.png) [@doreen](https://boards.straightdope.com/u/doreen)\ **Post date:** [July 9, 2021, 8:23pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/348 "2021-07-09T20:23:48Z")
Maybe I’m the one with a dumb question - but why would you want the bank to fill out the CTR if they weren’t required to? There are plenty of business that are or can be [exempt](https://www.fincen.gov/resources/statutes-regulations/guidance/guidance-determining-eligibility-exemption-currency) from CTR requirements. ---
**Author:** ![DrDeth](https://avatars.discourse-cdn.com/v4/letter/d/b487fb/32.png) [@DrDeth](https://boards.straightdope.com/u/DrDeth)\ **Post date:** [July 9, 2021, 8:27pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/349 "2021-07-09T20:27:57Z")
There is nothing for them to report. They can NOT file a CTR for under $10000, the Fincen site won’t even accept one. > [@k9bfriender](#): > > Or is it illegal to “structure” your deposits to make sure that they are over $10,000 and generate a report? No, since you are not avoiding the CTR and proper reporting. I really do not understand what you are getting at here. ---
**Author:** ![k9bfriender](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/k9bfriender/32/3283_2.png) [@k9bfriender](https://boards.straightdope.com/u/k9bfriender)\ **Post date:** [July 9, 2021, 8:40pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/350 "2021-07-09T20:40:00Z")
I was being a bit glib on that, as far as it being illegal. (I think) But the idea being that if you have a business that does regularly collect around $9000 a day in cash, legitimately, in order to avoid suspicion, you deposit every 2 days, so that you are above the threshold, ensuring that it is properly reported, and no one looks at you suspiciously for depositing just under the amount. ---
**Author:** ![Pleonast](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/pleonast/32/1183_2.png) [@Pleonast](https://boards.straightdope.com/u/Pleonast)\ **Post date:** [July 9, 2021, 9:00pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/351 "2021-07-09T21:00:38Z")
> [@doreen](#): > > Maybe I’m the one with a dumb question - but why would you want the bank to fill out the CTR if they weren’t required to? To avoid being accused of structuring your deposits. Lawyers cost money, so instead of having to explain your deposits, be proactive and report them. If all of your deposits are reported, then by definition there cannot be a crime of structuring. ---
**Author:** ![nearwildheaven](https://avatars.discourse-cdn.com/v4/letter/n/90db22/32.png) [@nearwildheaven](https://boards.straightdope.com/u/nearwildheaven)\ **Post date:** [July 9, 2021, 11:36pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/352 "2021-07-09T23:36:56Z")
A woman I know was working at a bank in late 1999, and had a customer who didn’t trust that the computer system would work after the new year, so she wanted her accounts liquidated to the minimum balance, and the cash placed in her safety deposit box. That bank had to order almost $100,000 in cash from the Federal Reserve, because even they didn’t have that much on hand, and she placed it in her lock box and retrieved it after the new year, and redeposited it into those accounts. ---
**Author:** ![bob\_2](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/bob_2/32/3341_2.png) [@bob\_2](https://boards.straightdope.com/u/bob_2)\ **Post date:** [July 11, 2021, 11:24am UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/353 "2021-07-11T11:24:48Z")
I suppose that anything is possible, but she clearly didn’t think it through: I assume that she would have had to pay bank charges for the two transactions. If the bank’s computers had failed on Y2K her box would have been inaccessible. If it was that serious, her Dollar bills would likely be worthless. ---
**Author:** ![doreen](https://avatars.discourse-cdn.com/v4/letter/d/858c86/32.png) [@doreen](https://boards.straightdope.com/u/doreen)\ **Post date:** [July 11, 2021, 11:43am UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/354 "2021-07-11T11:43:13Z")
Why would her box necessarily have been inaccessible if the computers failed ? I suppose that it’s possible that the bank might check that the box belongs to the person showing up with the key - but that doesn’t have to involve computer records. They might have printed a copy in anticipation of Y2K problems or she might even be personally known to the bank personnel (especially if they had to order $100K in cash for her to put it in her box) ---
**Author:** ![EnolaStraight](https://avatars.discourse-cdn.com/v4/letter/e/41988e/32.png) [@EnolaStraight](https://boards.straightdope.com/u/EnolaStraight)\ **Post date:** [July 11, 2021, 2:35pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/355 "2021-07-11T14:35:21Z")
How about a GoFundMe page? Any number of anonymous individuals could channel through cyberspace any amount of monies to pay for your…whatever. ---
**Author:** ![Whack-a-Mole](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/whack-a-mole/32/141_2.png) [@Whack-a-Mole](https://boards.straightdope.com/u/Whack-a-Mole)\ **Post date:** [July 11, 2021, 2:36pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/356 "2021-07-11T14:36:20Z")
Yeah…no way her deposit box would be inaccessible. If hers was than everyone’s was and that would be a BIG problem for the bank. If, somehow, Y2K made it impossible to verify their deposit box holders I think they would reach for a backup copy of the data and put it on a computer that they told the date was before the year 2000. Of course they thought of these issues ahead of time so, not a problem. Also, I would think the woman would be covered by FDIC insurance. ---
**Author:** ![bob\_2](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/bob_2/32/3341_2.png) [@bob\_2](https://boards.straightdope.com/u/bob_2)\ **Post date:** [July 11, 2021, 3:32pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/357 "2021-07-11T15:32:06Z")
I was kind of assuming a massive queue of frustrated customers wh were unable to use the ATMs or cash cheques etc. I am sure that the whole Y2K thing has been much discussed but this thread has wandered all over the place anyway. ---
**Author:** ![md-2000](https://avatars.discourse-cdn.com/v4/letter/m/9d8465/32.png) [@md-2000](https://boards.straightdope.com/u/md-2000)\ **Post date:** [July 12, 2021, 5:15am UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/358 "2021-07-12T05:15:43Z")
> [@EnolaStraight](#): > > How about a GoFundMe page? > > Any number of anonymous individuals could channel through cyberspace any amount of monies to pay for your…whatever. Again, we’re back to the two sides of laundering. task A is getting bills into the bank. Task B is getting that electronic money into your account in as plausible and seemingly legitimate income. GoFundMe doesn’t solve A - in fact, by relying on electronic donations, it does nothing for your pallet of small unmarked bulls. As for B - while maybe 10,000 people donated $100 so you could create the perfect Girlled Cheese Sandwich, all 10,000 will be recorded in the GoFundMe system - open to the FBI to go interview them (it’s a crime to lie to the FBI) to see why they donated. How do you find 10,000 people where at least 10% won’t tell the FBI “I got $200 in the mail provided I donated $100 to GCS Research”? There’s a serious flaw in any scheme that requires you to recruit hundreds or thousands of useful idiots. ---
**Author:** ![bob\_2](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/bob_2/32/3341_2.png) [@bob\_2](https://boards.straightdope.com/u/bob_2)\ **Post date:** [July 12, 2021, 9:21am UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/359 "2021-07-12T09:21:06Z")
With those unmarked bulls as well as the perfect Girlled Cheese Sandwich, you may be on a perfectly legal winner anyway 🙂 Just steer clear of china shops. EnolaStraight didn’t give enough detail to show how his scheme might work. As they describe it, it would probably just be a simple fraud. If cleaning up dirty money was easy, there would be no need for discussion. ---
**Author:** ![DrDeth](https://avatars.discourse-cdn.com/v4/letter/d/b487fb/32.png) [@DrDeth](https://boards.straightdope.com/u/DrDeth)\ **Post date:** [July 12, 2021, 3:40pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/360 "2021-07-12T15:40:36Z")
> [@doreen](#): > > possible that the bank might check that the box belongs to the person showing up with the key - but that doesn’t have to involve computer records. They might have printed a copy in anticipation of Y2K problems or she might even be personally known to the bank personnel (especially if they had to order $100K in cash for her to put it in her box) Maybe or maybe not. If the banking system fails, the banks will close. They might open just for a brief time for safety deposit box withdrawals, sure. ---
**Author:** ![DrDeth](https://avatars.discourse-cdn.com/v4/letter/d/b487fb/32.png) [@DrDeth](https://boards.straightdope.com/u/DrDeth)\ **Post date:** [July 12, 2021, 3:46pm UTC](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654/361 "2021-07-12T15:46:37Z")
> [@Whack-a-Mole](#): > > Also, I would think the woman would be covered by FDIC insurance. [FDIC: FDIC Consumer News Winter 2018 - Five Things to Know About Safe Deposit Boxes, Home Safes and Your Valuables](https://www.fdic.gov/consumers/consumer/news/cnwin18/fivethings.html#:~:text=A%20safe%20deposit%20box%20is,contents%20of%20safe%20deposit%20boxes). _A **safe deposit box** is not a **deposit** account. It is storage space provided by the bank, so the contents, including cash, checks or other valuables, are not **insured** by **FDIC deposit insurance** if damaged or stolen. Also, financial institutions generally do not **insure** the contents of **safe deposit boxes**._ [Previous page](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654.md?page=17) [Next page](https://boards.straightdope.com/t/the-hard-part-of-money-laundering/944654.md?page=19)