Regulatory Alerts2005-07-15
Added
FinCEN Ruling 2005-6 – Suspicious Activity Reporting (Structuring)
FinCEN clarifies that financial institutions must establish systems to detect and report structuring, defined as breaking up transactions to evade Bank Secrecy Act reporting or recordkeeping requirements, even when individual transactions do not trigger a currency transaction report. Institutions are required to file Suspicious Activity Reports for structuring involving or aggregating at least $5,000 in funds or assets under 31 C.F.R. § 103.18. The guidance specifies that monitoring parameters must be risk-based and commensurate with the institution's specific money laundering and terrorist financing risks rather than applying a uniform standard.
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