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Comment by gruez | Hacker News Reader

So if I want to get around it all I need to do is

* make sure the deposits are under $9000, but also not some amount that's "suspicious" like $8,999

* make sure the deposits happen on a regular interval

* make sure the deposits are at the same branch

I also suspect banks don't share information to generate SAR (eg. a deposit of $15,000 at one bank would generate a SAR, but a deposit of $7,500 at two banks on the same day won't generate a SAR), so if you need to deposit more cash then all you need to do is open more accounts at more banks.

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Yeah, they've thought of this. It's called structuring, and it's a crime[0].

Side note: I see this kind of response a lot on HN. Whenever a precisely-defined law or regulation comes up, there will be the inevitable tricksy engineers pointing out a bug in the program. Except they haven't read the whole program, but only a couple of stanzas. And it's not actually a program. It's not being interpreted by a computer, but by people. At a certain point, rules-laywering will get the actual lawyers to tell you to get out of here with that.

Repeating something I've written here before: Your adversaries are people, not bash scripts.

[0] https://www.law.cornell.edu/uscode/text/31/5324

Nothing says the bank can't go "hey this guy deposited $90k in cash this year". They may ask you where you're getting it; if you own a bunch of vending machines, you're probably fine. If your answers are evasive or don't make sense, you might be getting a SAR.

$10k is just the automatic threshold for a CTR. A $1 transaction could cause a SAR to be filed, if there was a reason for the bank to be suspicious of it.

That's why any real criminal activity will have a front. Chinese takeaway, vending machines, flower or newspaper vendor, second hand shop, ..

Those types of businesses get additional scrutiny from the financial fraud team for precisely the reason they're useful as front businesses (as well as tax evasion).

What does this look like? Does the bank ask for receipts if a Chinese restaurant wants to be their customer? Do they stake out the restaurant to see whether the foot traffic levels correspond to the claimed revenues?

Some banks do, some don't.

In a lot of countries if you establish a small company and open a bank account for it they will just do the bare minimum, after all if you got a tax number and just got a new company registered you already jumped through a few background check hoops.

Of course they will still run your name through their whatever systems. And eventually if your business starts transacting it'll be constantly looked at by the automated systems.

As long as you don't do anything suspicious, no one will care.

Basically if you behave like all the small shops that have to deposit cash, no one will look twice.

Also, cash is not interesting, the problem is when you start to wire money (or get transfers) to/from places that small kitchens usually don't. And that's when risk and compliance departments might notice the activity.

No, it compares this Chinese restaurant to the hundreds or thousands of other similar businesses who bank with it, in similar markets.

No, the bank doesn't ask for receipts or stake out businesses.

If that business has a transaction profile that's out of line with the 'similar business' model, they potentially get flagged.

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