"What's the Number Where You Fill Out That Form?"
Over three weeks, teller Priya has handled four cash deposits from Mr. Okafor into the same personal checking account: $9,200 on a Monday, $8,700 the following Wednesday, $9,500 the Friday after that, and $9,800 today. All are in mixed $50s and $100s, all arrive between 9:15 and 9:40 a.m., and all come with a deposit slip where the total is already written in. Mr. Okafor says he is a used-car dealer who works in cash because he does not trust banks with his sales receipts, and he has no business account at the branch. Today he asks Priya, “What's the number where you have to fill out that government form? I don't want any trouble - should I come back tomorrow with half of it?” No single deposit has exceeded $10,000, the bank has no other accounts for him, and bank policy requires currency to be aggregated by business day across all branches.
1. How should Priya answer the question about the threshold?
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She must not answer it as asked. Naming the figure, or confirming that splitting the deposit would keep him under it, is assistance in structuring - and structuring is a federal crime under 31 U.S.C. §5324 whether or not the underlying money is clean. The customer's intent does not have to be criminal for the advice to be unlawful; the offense is conducting transactions to evade the reporting requirement.
What she can say: “I'm not able to give advice about how to handle deposits to stay under a reporting threshold - that's not something the bank can help with, and splitting a deposit to avoid a report is itself a violation. The bank is required to report certain currency activity, and those reports are routine and confidential. I can take your deposit today exactly as you'd like to make it.”
What she must not do: quote the $10,000 figure, suggest he “come back tomorrow,” suggest a business account as a way around reporting, tell him whether a report will or will not be filed for him, or refuse the deposit and send him away. Refusing without a legitimate reason creates its own record problem and looks like tipping off.
The correct next step is behind the scenes: complete the transaction normally, note the conversation verbatim in the referral, and escalate to the BSA officer the same day.
2. Is any report required now? Walk through the CTR and SAR analysis.
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CTR: A Currency Transaction Report is required for currency transactions by or on behalf of one person that aggregate to more than $10,000 in a single business day. No single day here crosses that line, but two things must be checked before concluding none is due: whether he made any other cash transaction at another branch or through another channel on the same day, and whether any of the four deposits were on the same business day as another. Aggregation is bank-wide, not branch-level, and deposits to a personal account that are actually business receipts count as being on behalf of the business as well.
SAR: This is the stronger issue. The pattern - four cash deposits in the $8,700–$9,800 band, same time of day, same account, deposit slips pre-totalled, plus an explicit request for the reporting threshold and an offer to split the deposit - is a textbook structuring indicator. The SAR rule applies at $5,000, and both the individual deposits and the aggregate clear it. Priya does not decide; she files a complete internal referral to the BSA officer with dates, amounts, denominations, and the exact wording of the question. The BSA officer determines whether to file, and filing is due within 30 calendar days of that determination.
Confidentiality: Neither the CTR nor the SAR may be discussed with the customer. 31 U.S.C. §5318(g)(2) prohibits disclosing that a SAR was filed, and the reporting regulations prohibit disclosing report contents to the subject.
3. Mr. Okafor asks whether the bank can just “list him as exempt” so the paperwork stops. How should the branch respond, and what if he deposits $9,800 plus another $400 later the same day?
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The exemption answer is no, and the reasons are concrete. A Phase II exemption for a non-listed business requires, among other things: the business has maintained its account at the bank for at least twelve months, frequently engages in currency transactions with the bank, deposits or withdraws more than $1,000,000 in currency in the prior twelve months, and the account activity is reasonably related to the business. Mr. Okafor has no business account, has been depositing roughly $37,000 over three weeks at a personal account, and - decisively - an exemption may not be granted where there is suspicion of structuring. Granting one here would look like a deliberate mechanism for suppressing reports. Exemption decisions belong to the BSA officer and compliance, are documented on the designated form, and are reviewed annually.
On the second question: if he deposits $9,800 and then another $400 in currency later the same business day, the aggregate is $10,200 and a CTR is required. The deposit must be accepted; the teller does not warn him, does not refuse the second deposit, and does not “hold” the first one until tomorrow to keep the total down. The teller completes the transaction, captures his identification and the source of the currency, and routes the CTR and the existing structuring referral to the BSA officer, noting that the pattern continued after the conversation.