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CFCI: Financial Crimes: Scheme Mechanics, BSA Reporting, and the Documentary Trail

CFCI · Work through your exam, one topic at a time.

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Financial Crimes: Scheme Mechanics, BSA Reporting, and the Documentary Trail

The Financial Crimes domain tests whether you can name a scheme's mechanics, attach the right statute, and build a documentary trail that survives prosecution. Expect questions on check and card fraud, identity crime, money laundering, and the Bank Secrecy Act rules that generate most of the paper an investigator works from.

Scheme families and matching statutes

  • Check and deposit fraud: kiting, counterfeit items, forged endorsements, altered checks. Bank fraud under 18 U.S.C. §1344; mail or wire fraud (§1341/§1343) where a carrier or interstate wire is used.
  • Payment cards: skimming at POS or ATM, card-not-present fraud, chargeback abuse, BIN attacks.
  • Identity crime: true-name theft and synthetic identities; 18 U.S.C. §1028 and §1028A.
  • Money laundering: placement, layering, integration. §1956 requires intent to promote or conceal; §1957 covers criminally derived property over $10,000.

BSA reporting you must not confuse

  • CTR: currency transactions over $10,000 by or for one person in one business day, aggregated across branches.
  • SAR: generally $5,000+ for banks and $2,000+ for money services businesses; insider abuse at any amount. File within 30 days of detection, 60 if no suspect is identified.
  • Structuring, 31 U.S.C. §5324: intentionally evading the CTR threshold. The source of the funds is irrelevant to the offense.

Worked example

A subject deposits $9,400, $9,600, and $9,000 in cash at three branches before noon. No single deposit exceeds $10,000, but the bank aggregates by customer per business day, so a CTR is required and its absence is itself a red flag. The pattern (amounts just under threshold, multiple locations, short window) supports a structuring charge even if the money came from a legitimate business. The investigator documents teller identities, timestamps, and branch camera coverage, then confirms whether a SAR was filed and reviews prior account activity for the same pattern.

Traps that cost marks

  • Assuming structuring requires illegally sourced funds; it does not.
  • Treating SAR and CTR thresholds as interchangeable.
  • Relying on victim interviews alone; answers reward documentary corroboration.
  • Missing beneficial ownership when the account is held by an LLC or nominee.
  • Ignoring that a CTR is triggered by cash, not by wires or checks.