[privacy] FW: What Is "Structuring" and How Do Banks Detect It?

["Larry Seltzer" <Larry () larryseltzer com>]

Just another pitch I got today
Larry Seltzer
eWEEK.com Security Center Editor
http://security.eweek.com/ <http://security.eweek.com/> 
<http://blogs.pcmag.com/securitywatch/>
http://blogs.pcmag.com/securitywatch/
<http://blogs.pcmag.com/securitywatch/Contributing> 
Contributing Editor, PC Magazine
larry.seltzer () ziffdavisenterprise com 
________________________________

From: Temin and Company [mailto:news () Teminandco com] 
Sent: Wednesday, March 12, 2008 4:18 PM
To: Temin and Company
Subject: What Is "Structuring" and How Do Banks Detect It?



Fortent has been getting numerous calls asking for an explanation of
"structuring" and how banks detect it. Following is a primer on the form
of money laundering called "structuring." If you would like more
information about this, or to speak with Fortent experts, please contact
Suzanne Oaks or Davia Temin of Temin and Company at 212-588-8788 or
news () teminandco com <mailto:news () teminandco com> . 

 

 

A Primer on "Structuring" as a Form of Money Laundering 



NEW YORK - March 12, 2008 - A commonly-used form of money laundering
called "structuring" has recently emerged in the news. 

 

Dr. Michael Recce, Chief Scientist at Fortent, the risk and compliance
technology and information company, explains: "Structuring is a favorite
method used by money launderers to attempt to avoid detection. 

 

"Due to the Bank Secrecy Act and the USA PATRIOT Act regulations, banks
are required to report customer transactions of $10,000 or more to
federal authorities. So in order to get around these requirements, an
individual could 'structure' or divide payments into a set of
transactions where each individual transaction is below this $10,000
threshold. This maneuver increases the chances that the individual would
fly under the radar of banks' compliance departments.

 

"Divided transactions raise suspicion levels, and banks have systems in
place to detect just this sort of criminal behavior."

 

Common signs of structuring, says Dr. Recce, include:


1. Movement of cash in multiple transactions under $10,000 - "Obviously,
not every transaction of under $10,000 is suspect, but if banks see a
pattern of cash movement to the same account when it doesn't seem to
make sense, this raises red flags."

 

2. Attempts to take the sender's name off wire transfers - "If you have
nothing to hide, why would you try to conceal your transactions?"

 

3. Large cash deposits made to ATMs - "Most people deposit checks, not
cash, into ATMs, so banks' systems tend to raise red flags for these
types of transactions."

"To detect structuring," says Dr. Recce, "anti-money laundering systems,
such as Fortent's, look for situations in which multiple transactions of
slightly under $10,000 are performed within short periods of time,
possibly at multiple branches or locations of a bank."

 

 

About Fortent

Fortent provides risk and compliance solutions to financial
institutions, government agencies, and individuals in more than 100
countries. With advanced systems endorsed by the American Bankers
Association, Fortent's market-leading technology, information, and
training businesses help clients fight financial crime and achieve
regulatory compliance throughout their global operations.

 

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