The hard part of money laundering

I find that to be a bit more confusing now. Is currency only cash, or is currency any form of money?

According to:

Doesn’t sound like its limited to cash. Wonder if someone more personally knowledgeable, like @DrDeth can weigh in on how to interpret that.

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?

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.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.

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.

Cool thanks. That’s what I was thinking, but I found that Investopedia page pretty ambiguous.

I do sometimes look a bit suspicious. :sunglasses:

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.

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?

Or is it illegal to “structure” your deposits to make sure that they are over $10,000 and generate a report?

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 from CTR requirements.

There is nothing for them to report. They can NOT file a CTR for under $10000, the Fincen site won’t even accept one.

No, since you are not avoiding the CTR and proper reporting.

I really do not understand what you are getting at here.

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.

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.

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.

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.

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)

How about a GoFundMe page?

Any number of anonymous individuals could channel through cyberspace any amount of monies to pay for your…whatever.

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.

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.

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.

With those unmarked bulls as well as the perfect Girlled Cheese Sandwich, you may be on a perfectly legal winner anyway :slight_smile: 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.

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.

FDIC: FDIC Consumer News Winter 2018 - Five Things to Know About Safe Deposit Boxes, Home Safes and Your Valuables.

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 .