That's what some thought when buying Chase gcs...

You're misunderstanding. I said nothing about using the same bank that issued the CC.

No. You're paranoid and we're not. That's the difference of opinion in a nutshell. There's no justification or rationalization here, only reason.

Any activity taken to avoid the required reporting can qualify, IMHO.

Yes. With structuring, I understand that it has to have some kind of splits to avoid the required reporting...but that's not what we do or at least that's not what I do. I either "combine" multiple VISA/MC GCs instead of "splits" or use a single VISA/MC GC for whatever the purpose...so I am a bit confused.

I would agree. While the probability of getting into trouble may be very low it isn't zero, and the consequences are high. Are there real world cases of people charged and convicted solely of structuring? Yes, there are some. It does usually involve other criminal activity but not always. There are some web sites dedicated to highlighting these as abuses of government power.
I can tell you from discussions from other FI professionals that in some districts, a SAR filing for structuring results in a freeze order showing up for the account soon after.

Warning, soap box rant ahead.

It is foolish to stray outside of the law...even if the dollar thresholds seem low because they are not adjusted for inflation.
And it is even more foolish to talk about doing it on FT when you have no idea who is in the audience.

<End rant>

This is a critical point. If you have a valid reason for doing something it isn't structuring. For example, we've had instances where someone always deposited just under 10k each day...that screams structuring. However, after checking with them (and their insurance carrier) we determined that they were doing it because their insurance bond required them to have no more than 10k on hand at anytime. That's not structuring and we were able to exempt their account.

I understand that structuring is not the same as avoiding a CTR. You have to have a underlying evidence that large money were split into pieces.

A SAR is reported in this instance, no? It's very suspicious to me even with the verification. "To have no more than $10k on hand at any time," that means this person was draining near $10k everyday and depositing near $10k everyday...also, isn't this person have to be doing this on behalf of a corporation or something to be the "exempt person", no?

I should have been more specific. Their business (store) was generating around that amount each day (sometimes more or less) but they were always bringing in right under 10k because of the insurance issue. In other words, if they were bring 11k to the bank and got robbed they would not be covered. After investigating their insurance and tax payments we gave them an exemption...there is a part of the FinCEN regs that allow this for a business but it is limited.
This was a specific case I was using to show that intent matters, but it probably isn't relevant to what everyone was talking about.

That's what I read. I'm glad that things are reflected in the real world.

http://www.fincen.gov/news_room/rp/f...backReport.pdf
http://www.fincen.gov/whatsnew/pdf/CTRPamphletBW.pdf

I was going to post a pretty flippant comment about the paranoia level here, but instead let me put it more constructively.

I believe the risk of being accused of structuring is miniscule. The risk of being convicted of it significantly lower again. But even as a raging bull on the MO game, I would agree the risk is not 0, unless you are rounding to at least I would say 10 decimal places. Of course the potential consequences could be huge. We call this tail risk.

The best defense is to not act in a manner that is consistent with structuring activity. If I have half a dozen bank accounts, and one day I obtain $10k in money orders and deposit them in one, and the next day I obtain $8k and put them in another and so on that is not structuring. If one day I obtain $30k in money orders and break it up into 4 $7500 deposits in an attempt to avoid reporting requirements, while I still stick with my risk probabilities above, there is some possibility that could be painted as structuring.

However you are doing it, keep a good paper trail so in the highly unlikely event something happens you can show what you were doing and why. And if you think my risk probability above is too aggressive, just don't play this game and find another sand box to moan in.

Links, please.

Great posts AnalystGuy, they are really appreciated. I am not a real player in this as I buy $1,000 - $2,000 at a time every once in a while at WalMart and usually pay off credit card balances with them, but I have intellectual curiousity about the subject and I have no problem or criticism with others doing more. I was surprised to see when reading the Structuring law that it appears to technically apply to transactions designed to minimize the bank's internal monetary reporting regarding the $3,000 limit. But virtually all of the cases available on the Internet involve the $10,000 CTR limit. In practicality, do you see structuring concerns regarding the $3k limit, which is just not very much money.

Risk tolerance is different for everyone. It is prudent to understand the possible ramifications of your actions so you can make an informed decision.

The government can and does make examples of people. The government can and does change their priorities and policies on enforcement. Ask Credit Suisse and the other Swiss banks how things are working out for them.

Great posts AnalystGuy, they are really appreciated. I am not a real player in this as I buy $1,000 - $2,000 at a time every once in a while at WalMart and usually pay off credit card balances with them, but I have intellectual curiousity about the subject and I have no problem or criticism with others doing more. I was surprised to see when reading the Structuring law that it appears to technically apply to transactions designed to minimize the bank's internal monetary reporting regarding the $3,000 limit. But virtually all of the cases available on the Internet involve the $10,000 CTR limit. In practicality, do you see structuring concerns regarding the $3k limit, which is just not very much money.