Are there any timing guidelines or accepted best practices for determining if a customer is structuring? For example, if they have cash transactions that add up to a little over $10k, but they've spread them out over several days (usually 7 or 8, sometimes up to 11-13 days). I typically think of structuring occurring within about 5 days or so, but I don't know why I think that. I have a customer who spreads them out over a week or more.

For example:

5/30/17: $1,296.11
5/31/17: $2,756
6/5/17: $3,125
6/6/17: $3,467
6/7/17: $100

= $10,744.11

The above transactions occurred within 8 days. Just need some clarity on this. Do you consider this structuring? What if they seem to be spread out over a period of a couple weeks? The customer has regular cash, so I'm having a hard time determining if they are doing this on purpose and if it's reportable.

We do not consider regular cash deposits to be normal in a consumer account. We would request the account officer talk to the customer and determine the source of the cash. Often, it's really business activity and a new business account gets opened. If they tell us something like 'gambling winnings' or 'bringing cash from other banks' we ask if they would mind providing some documentary verification. If they refuse, we tell them we are unable to accept further cash deposits to the account (of any significance).

Depending on what you learn, a SAR may indeed be needed, for structuring or for unusual cash.

At least that is how we TRY to roll, and how we train. The reality does involve back and forth with the business line. If you don't get a quick answer, you might file the first SAR and hope to get it cleared up before 90 days is up.

Personal opinion: You need to think it likely that your customer started out with more than $10K in cash and broke it down for the sole purpose of avoiding the CTR before "structuring" is a reasonable accusation. I'm trying not to be overly persuaded by the odd dollars and odd cents, but your numbers alone do not give me a "structuring" vibe.

Regardless, as noted, you have the basis for asking a consumer customer: Whussup? regarding the source of the cash. I've heard both credible and incredible explanations of similar activity. Also as noted, sometimes you are looking at business, not consumer, activity and the account relationship needs to be revised.

The odd dollars lend themselves more to business activity than nefarious deeds. However, I will also be looking at the overall cash in for the year, if it turns out to be a business. If it's a lot, we would consider a tax evasion SAR. If he is comingling cash into his personal account, we would be skeptical he's paying taxes on it. Or, we could just tell him to go and sin no more. Depends on facts and circumstances. Maybe he has a loan with you and you can see his tax returns. Maybe it's something small and seasonal that he does on the side--grow orchids?