Structuring Signals in a Deposit Pattern
A teller refers a walk-in customer to you. Over the past nine working days the customer has made seven cash deposits into a personal account: PKR 480,000, PKR 495,000, PKR 470,000, PKR 500,000, PKR 490,000, PKR 485,000 and PKR 475,000. Each deposit is just under PKR 500,000. The account was opened four months ago with a declared monthly income of PKR 120,000 and an occupation of 'property consultant'. The customer is polite, says the money is from 'selling a plot', and becomes evasive when asked for the buyer's name. Total deposits are PKR 3,395,000. The branch's AML/CFT procedure requires a suspicious transaction report to be considered when transactions have no apparent economic rationale.
1. Analyse whether this pattern meets the threshold for escalation. Identify the specific red flags and compute the relevant totals.
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Totals. Seven deposits sum to PKR 3,395,000 in nine working days, an average of about PKR 485,000. Declared monthly income is PKR 120,000, so deposits are roughly 28 times monthly income in under two weeks.
Red flags.
- Structuring pattern: every deposit sits just below PKR 500,000, a classic attempt to stay under a reporting or scrutiny threshold. The consistency of the amounts is itself suspicious - genuine plot sales do not arrive in seven near-identical slices.
- Mismatch with profile: a property consultant declaring PKR 120,000 per month cannot plausibly generate PKR 3.4 million in cash in nine days.
- Evasive explanation: refusal to name the buyer undermines the 'plot sale' story; a genuine sale has a documented buyer, deed, and payment trail.
- Cash-intensive, rapid turnover: repeated cash deposits into a newly opened account are a recognised placement indicator.
Conclusion. The pattern has no apparent economic rationale consistent with the profile and shows deliberate threshold avoidance. It meets the escalation threshold. The correct action is to raise an internal suspicious transaction report for the compliance/MLRO function to decide on filing with the Financial Monitoring Unit; the branch does not decide alone and must not tip off the customer.
2. The customer asks whether the bank will report him and threatens to move his account. How do you handle the conversation, and what must you not do?
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What to do. Stay calm and neutral. Complete the transaction if it is otherwise in order and within your authority - refusing solely because of suspicion, without a lawful basis, can itself create risk. Ask routine customer-due-diligence questions about the source of funds in a normal tone, record the answers verbatim, and note the evasiveness. Explain that the bank routinely asks for source-of-funds information on large cash deposits and that this is standard practice, not an accusation.
What you must not do - the tipping-off prohibition.
- Do not tell the customer that a suspicious transaction report is being or may be filed.
- Do not hint that his pattern has been flagged or that he is 'under review'.
- Do not promise that no report will be made, and do not bargain about reporting.
- Do not alter, split, or delay the record to avoid scrutiny.
Escalation. Refer the matter internally to the MLRO/compliance function with your notes, the deposit schedule, and the customer's statements. If the customer insists on closing the account, process it normally and preserve all records; account closure does not extinguish the reporting obligation. Document the threat and your response in the file.