What is a timeframe for structuring a day or two, five or six days, eight days or two weeks after the first initial deposit? Just trying to figure out if there is any guidance for the timeframe for structuring?

I look at how many days between deposits and the deposit amounts and if it looks like a pattern. I do not think there is a guide that would really tell you exactly what you should consider structuring. If it is suspicious, then I send it to committee and we usually end up filing a SAR. Some banks have rules systems and they have certain guidelines they would use internally to determine structuring, but I do the above.

What if there is not a pattern? Just two deposits a week apart that go over the threshold?

I don't recall seeing any firm guidance. I have seen FinCEN use terms such as 'multiple days' (which I take to be one after another) and 'over a period of several days or more'.

When I review history for structuring, I would focus on the dollar amounts (are they in the aggregate going over the $10,000) and how frequently are the transactions done?

It would have to be a judgment call on your part. Sometimes, you can ask your tellers and they know more about the customer and why they are making deposits or withdrawals. For me, it still goes back to if you think it is suspicious file a SAR, you can never go wrong by doing so.

What has the customer's cash activity been prior to those two transactions? Given what you know about the customer, could these just be two isolated transactions?

The question should be is the customer structuring to avoid filing of a CTR?

or did the customer reasonably obtain the funds and deposit it legally.

I would also suggest you look very closely at where the money went.

I have a customer that normally does not deposit more than $100 in cash occasionally. I see a $8,000 cash deposit on Monday and 10 days later I see a $6,000 cash deposit.

Two days later the customer comes in an gets a $14,000 cashier's check made payable to a car dealership.

Everything is subjective, but you be the judge.

You answered the question when you posted it. If you suspect the customer is structuring, he is.

There is no formula...

Like the rest of the folks on this post are saying, there isn't a set-in-stone rule when in comes to determining structuring, as they should be treated accordingly case by case. It's a judgment call by you or whoever that has the final say.

IMHO and based on your description, assuming the funds remain on deposit, I wouldn't necessarily deem it as structuring, just yet. What I would do is put that customer's accounts on watch for the next 3 to 6 months (or whatever the range you feel comfortable with) to see if any suspicious activity or pattern develops.

Good luck.