Will I need to worry about "structuring" with wire transfers?
I am moving a large (for me) amount of money from a US bank account to a Danish one. Both are in my name. In order to even out the risk of transient exchange-rate spikes I'm planning to do it as a series of wire transfers on different days.
Balancing things between per-transfer fees and the exchange-rate swings I want to guard against, it so works out that I would ideally like to do the transfers in chunks of about ,000.
However, I dimly remember something about people getting into trouble with the law if they do a series of similar transactions just below ,000 each. In some tellings it sounds like this is only a problem for transactions with physical cash, but I can't find any hard information about this.
Do I need to change my plan to make at least some of the chunks larger than ,000 (or even €10,000), such that it doesn't look like I'm trying to evade something?
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In the US, currency transactions of more than ,000 require a Currency Transaction Report (CTR) to be filled out and submitted to the Financial Crimes Enforcement Network (FinCEN). Note than FinCEN is a sister bureau to the IRS, both of which fall under the umbrella of the Treasury Department.
A CTR is required only when dealing with monetary instruments, which are defined as:
3)“monetary instruments” means— (A)United States coins and currency; (B)as the Secretary may prescribe by regulation, coins and currency of a foreign country, travelers’ checks, bearer negotiable instruments, bearer investment securities, bearer securities, stock on which title is passed on delivery, and similar material; and (C)as the Secretary of the Treasury shall provide by regulation for purposes of sections 5316 and 5331, checks, drafts, notes, money orders, and other similar instruments which are drawn on or by a foreign financial institution and are not in bearer form.
The basic idea is that monetary instruments are "cash-like" since they can be transferred from one person to another without any form of tracking. This is why a CTR is required for large cash-like transactions.
Wire transfers by themselves are not considered a monetary instrument and therefore would not require a CTR. (Because they are already tracked by the normal banking mechanism.) Multiple wire transfers of under K would normally not trigger an SAR (Suspicious Activity Report) unless someone at the bank decided to report one for any reason.
However, if the source funds of the wire transfer are a monetary instrument, or if the recipient takes the wired funds in the form of a monetary instrument, then amounts over K would trigger a CTR just as it normally would.
The law in the United States is related to cash transactions. It doesn't include those transactions done electronically, by wire transfer, or by check. The structuring part of the law applies to those people trying to keep the cash transactions under K by making multiple transactions.
The law is designed to flag people that may be dealing in cash business that are not reporting their income. It is not used to flag the exchange of funds by legitimate methods.
The law does not just apply to traditional banks, it also is a requirement for those business that people with large amounts of cash might try and launder funds through. That is why you can pay for a car with a check, but you will run into problems if you bring a briefcase full of cash.
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