ACAMS Today, Sept-Nov 2023 September-November 2023 | Seite 20
AFC CHALLENGES
Structuring :
AML ’ s reddest flag
There seems to be regular if not constant , debate in anti-money laundering / Bank Secrecy Act ( AML / BSA ) compliance circles about finding ways to reduce the “ burden ” of filing suspicious activity reports ( SARs ) based on structuring ( also known as smurfing ). Structuring currency seems to have taken on a persona that it is more of a nuisance to AML detection and compliance efforts than a potentially valuable investigative lead with which it is more often associated . The debates and discussions include potentially increasing filing thresholds , streamlining the narratives or basically turning them into a “ cut and paste ” template . The real question should be how this reddest of red flags in AML has obtained a diminished status .