We have a mission organization with whom we have been doing business since 2002. They had been doing one wire a month and recently have increased to several a month. The odd thing is that a number of their wires are exactly $9,900. They told our wire personnel that this is all that Guatemala allows them to send at one time. Does anyone know about wire limits to Guat?

I do not know about Guatemala, but I have never heard of a country limiting amounts sent in, only amounts sent out.

Call the Guatemala embassy, they should be able to help.

I've heard the same thing with Taiwan a while back. Nothing reportable here, you can't enforce Guatemala law here right?

It is reportable if you want it to be reportable. The increase in wire activity and the "somewhat" obvious attempt to structure would all indicate something reportable. As BC78a said, contact the Guatemalan embassy:

http://www.traveldocs.com/gt/embassy.htm

I have filed SARs for structuring to avoid another country's money control laws.

Structuring what? Why would you file on foreign law? To me, if its NOT a US violation then it's not reportable. IMHO. We are certainly not obligated to file.

Would i exercise caution going forward with a particular customer? I sure will.

An institution must file a SAR “if it knows, suspects, or has reason to suspect that any crime or any suspicious transaction related to money laundering activity or a violation of the Bank Secrecy Act has occurred” The requirement does not say a crime in the US.

If someone is structuring a wire out of country “A” to your bank in the US so it avoids country “A’s” money control laws, this is a crime, and should be reported on a SAR.

Just my opinion for what it is worth

Sure BC78a, i agree with your first paragraph.

Structuring a wire? There's no such thing according to the BSA, USA Patriot Act OR the FFIEC manual. Certainly no mention of structuring wires in Appendix G.

I respect your opinion but i disagree.

So we agree to disagree, I am fine with that.

Enjoy your day

If they were trying to avoid record keeping requirements in Guatemala, they would have to be sending wires for less than the equivalent of $2,000 US dollars.

I think someone is blowing smoke on the $9,900 and I would be taking a closer look at the source of these funds.

Guatelama

i like the sound of that. :-)

FYI
CHINA- $50,000 – wire fee (~$49,985 this is the key amount) wire limits per day, per person to avoid foreign government reporting requirement.