Amex are some of my best accounts

Thank you, Mamibear. I read a lot of your posts and find them very helpful!

I guess I haven't looked much at offers on my Starwood card. I called to cancel the thing and got a statement credit for a little more than my fee for this last year, but it's coming due again, and I doubt they will give me a statement credit again.

Several years ago, we used the Amex to buy SM VGC's to build miles. I stopped when the fee went up, and liquidating is tougher where we live.

I used to spend a lot on the Starwood card, but the flights with no blackout dates were not a good value. My points were only worth about 1 cent each. I used to deposit with Alaska for the 25% bonus, but that didn't give me the value I can get from the UR Portal with Chase. Now with the Chase Sapphire, I get 3X on my maintenance fees.

I did transfer my Starwood points, all through Amex spend, 90K to Marriott and got 270K for the SW companion pass and five nights in a Marriott Category 8 hotel.

Hands down Amex is the most lucrative issuer if you know what you are doing.

If any bank was penalized for not reporting non-currency transactions, then they had poor legal representation. But, I'd guess that currency was involved. But you're right, WM, CVS, and other MSBs are taking a CYA position on reoporting/record-keeping. Selfishly, I wish they wouldn't, of course.

Also, I'd never advise anyone to be cavalier about this hobby. Even if I believe it's impossible to structure in non-currency transactions, I avoid the appearance of structuring. The process is the punishment in many cases.

Andyandy

You're right that SARs are the most subjective of the AML measures and don't neccessarily require currency to be involved. SARs can be triggered by non-currency transactions a bank has reason to know or suspect to involve funds from illegal activity or that serve no apparent lawful purpose. That's one reason that I am always straightforward about what I'm doing and why I believe it's good practice to develop relationships with clerks and tellers.

Andyandy

The guidance (granted it is instructive not statutory) tells a bank to gain an understanding of the entire stream of transactions in determining whether to file Suspicious Activity Reports. If someone deposits $250,000 a year in money orders in a bank account, the bank makes no effort to gain an understanding of the source of those deposits, and the government imposes a subjective penalty, I would be impressed with the attorney that got it reversed. We would like to think that explaining to the bank that the money orders were effectively purchased on credit as part of MSing should suffice, but the bank has no realistic way of documenting that those money orders were not purchased with cash.

Although I agree with you that money orders are not currency, if I were a bank executive I would prefer to close accounts with excessive money order deposits rather than take my chances with the penalty system. Where is the risk/reward? Even if the chance of a penalty is small, the bank makes no profit from such a deposit account.

I realize a lot of FTers are (or were) anti-bank. They were always justifying dumping dollar coins on the banks because the banks got bailed out. I dumped them too, I just didn't try to justify it. But listen to the banks arguments regarding the penalties they now face on liar loans.

1. The government regulations (and there were plenty of them even back then), did not require income verification.

2. We, the bank, did not get income verification.

3. The customer lied about his or her income.

4. The bank sold a certain number of these loans to generate immediate cash and to diversify risk in normal business transactions,

5. When the loans started to go bad, the banks took a hit.

6. The government passed programs to attempt to let the homeowners stay in their homes while not paying on the loans, and provided tax relief when the very people who originally lied about their incomes eventually defaulted.

7. Now the government levies enormous subjective fines and penalties against banks who made and sold bad loans.

There is no letter of the law enforcement in that situation. I am just saying that a bank has to be concerned about subjectiveness in addition to a precise reading of the law.

BINGO!!! Even if you look at it from common sense point of view (live aside the intelligent POV) it should tell you that the kind of volume is involved, even when it is non-cash, one needs to be diligent. Goes without saying cash of that kind would certainly invite some trouble.

Common sense again: That is why it is called "Suspicious activity", can not be limited to Cash only.

You're right. If there is actual illegal activity at the source of the stream, and the bank failed to make any inquiry or failed to heed facially suspicious aspects of the stream, they're probably out of luck. But, unlike CTR reporting and currency record-keeping requirements, I'd be surprised if a penalty stood in the absence of any illegal activity. But that's really neither here nor there for us, as there is no illegal activity involved in the traditional credit card-ppdc-money order-bank-credit card payment cycle.

Here's a decent thumbnail sketch of SAR reporting from a legal perspective:
https://www.wilmerhale.com/uploadedF...AR-Filings.pdf
The enforcement actions discussed towards the end are some examples of the successful imposition of penalties for failure to file SARs. But, you'll note that both involved illegal activity as the actual source of the funds involved.

Andyandy

"Law enforcement also may send a letter requesting that the account on which a SAR was filed remain open"... we just need to figure out how to trigger that :)

Anyone doing any kind of volume is raising eyebrows whether they think they are or not. There's also the very real possibility that they had a SAR filed without knowing. I've had a PO worker photocopy my DL for a $1K split transaction. I've had MO agents tell me that what I do looks shady. Bankers ask why I deposit so many MO's. My SM rep calls me a gamer. Stores change policy because of me (no more CC for VGC's, etc). I hope they believe my true explanation of MS, but if I were CSR, I would certainly be suspicious of anyone doing what we do...even if they said it was MS.

Don't underestimate the suspicious appearance of MS. Keep good paperwork and records so that in case the unlikely happens and you're investigated, you have solid proof that what you're doing is legal.

Your ways of using your SPG pts are probably not the optimal one.

Before the Marriott merger, our SPG pts are strictly used for hotel stays which often brought 2 to 3 pennies worth. I guess it depends on how much you travel and where you travel. As an example, in May we stayed at the one year old Sheraton Dubrovnik at 3/4K a night when the hotel was at over 130 euro a night and the acceptable local apartments were all close to 80 euro a night.

The Marriott transfer ratio and the Marriott Gold match are a very valuable benefit we are taking full advantage of. Already redeemed a Cat 7 package with the miles to AS. Plan to redeem 2 to 3 more in late 2017 also to AS which by far offers the most value to us as all our travels are International. Never fly WN and most likely never will. If I have to pick a carrier for domestic travel I would pick JetBlue for their Mint class. Though still quite irrelevant given 0 pure domestic trip for us.

AMEX cards as Mamibear said, are very lucrative IF you know how to use them.

I entirely agree with your post and have consistently taken a position, don't listen to those who say SAR applies only when Cash is involved. No, how it's done, how much, frequency...everything matters. That's simply plain wrong and it can harm someone in a big way.

As far as paperwork, Even if you didn't keep any paperwork, it is all traceable. Isn't it? Credit card statements will have all the charges, the bank statements would have deposits. You have used credit/debit, it's all electronic transactions. I'm not worried so much about the records, what I'm worried about, why deposits in so many banks? That would be hard to defend, all the other ones are easily explainable.

That is kinda...if you buy say $5k of VISA GCs and max is $500 per card, you can't prove anything about the link of CC -> GCs -> MO -> Bank unless you keep your receipts indicating exactly what CC you used to purchase what GCs and what GCs were used to buy what MO. And, this is only partial evidence since receipt never shows the full CC/GC numbers but only last 4. Plus, venders don't keep more than 3 months of records at the store or something like that (I'm sure the number varies by the venders like WM, CVS, etc., etc.)

If we deposit all MOs in 1 bank it would most likely be shutdown?

I'm thinking we only need to keep few to show as a sample,not necessarily every receipt. As long as you have explained the process honestly and truthfully. I understand your point regarding CC/bank account might be closed. Law and enforcement agencies should be able to get this for at least few years. Again, I wouldn't argue against someone wanting to be meticulous about record keeping. If you can keep records to the dot then all the more power to you.

When enforcement comes after you, they would have actually traced all these transactions before they even question you whether the accounts are active or closed.

Although true, That can't be used to defend yourself, that would be used against you, is it not?