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Talking to Customers About Structuring Can Look Like a Tip-off to Regulators

By Brian Monroe

Just three years ago, if Juan Llanos thought a customer might be breaking large transactions into small ones for a legitimate reason he would call or invite the customer in to his office and educate them about laws prohibiting structuring to avoid anti-money laundering reporting requirements. Not today. If Llanos, a director of compliance for New York-based money services business Unidos Financial Services Inc., has even the slightest suspicion that someone could be evading reporting requirements on purpose or simply doesn't know the law, he usually reaches for a suspicious activity reporting (SAR) form. "It's just too risky," he said,...

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