Can a bank set policy limits just under the reporting thresholds for monetary instruments and CTR filings when dealing with non-customers and not assume any risk liability under the BSA structuring rules?

In my experience, by setting the threshold limits just under the reporting levels, you set yourself up for structuring and increase your workload for SAR reporting.

As you work on your plan, don't forget that we now have FinCEN guidance on the $3,000 rule. We must maintain records of sales of monetary instruments $3,000-$10,000 even if we require the customer to put the cash in an account first.