Membership Development Team
Bankers Alliance
P. O. Box 162407
Austin, TX 78716
Phone:  (888) 353-3933
Email
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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for small-to-medium community banks across the U.S. — the only all-inclusive banking compliance advisory. C/A’s nearly 1700 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 28 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

We have a customer that has made 3 withdrawals on 3 consecutive business days of $8,000, $7,000, and $2,500. At what point can I or do I say they are structuring?    

Answer:

This will likely ultimately require an internal determination by the bank based upon any applicable internal/investor guidelines, or historical practices, as the definition of “structuring” seems to suggest that the term can be applied to a transaction of “any amount”, so long as the facts of the situation meet the definition of the term below:

“Structuring transactions occurs when a person, 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 institutions, on one or more days, in any manner, for the purpose of evading the CTR requirements.”

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