I ran afoul of the BSA/AML regs when taking advantage of an opportunity to purchase additional collectibles at a very good price.The Annoyed Man wrote:Yeah, and just try to make three consecutive cash withdrawals of $4,999. The law says that a bank is supposed to flag $5000 cash withdrawals for the fed gov't, but the fact is that people have been arrested for cash withdrawals smaller than that, and their assets seized on spurious grounds. It's about control. 100%.MechAg94 wrote:If the Govt got rid of cash, something would immediately take it's place. It might be coins, it might be bottles of Tide, or toilet paper. There will always be a black market that will have some kind of cash equivalent for trade in addition to the people who just want something outside of the electronic currency.
My thought about Govt control was about government taking control of pay and income as well as just the money.
After evaluating a collection where the owner was considering a partial sale, I made a cash offer for the pieces he had identified as being for sell. Upon acceptance of my offer, I went to my bank and drew $XX,XXX in U.S. currency to complete the transaction. While carrying my purchases out to my vehicle, the lady of the house informed me that should I care to, more collectibles might be for purchase. Back to the bank $X,XXX withdrawal. Back to the seller, "how much ya give me for the rest?" Back to the bank $X,XXX withdrawal.
In addition to the "CTR" (cash transaction report)from the first withdrawal my bank also generated a "SAR" (suspicious activity report) on the 2 smaller withdrawals. These reports led to a nice young man from the irs contacting me to determine if I had indeed attempted to "structure" my transactions to avoid the $10,000 report trigger. A short conversation and a couple of faxes of the purchase receipts and we were green again.
Due to public outrage and some Congressional scrutiny the irs and doj stopped seizures of assets in 2014 were there was no criminal activity revealed during investigation. In many instances the structuring took place because a teller or the cashier at the financial institution suggested the lower amounts to save the time involved in filing the "CTR".
The majority of the seizures that took place under the old rules can be recovered under the new. Filing a petition is not that onerous and bunches of folks have done so.
In almost 40 years of collecting and completing probably hundreds of large cash transactions this was the single time that I didn't (unknowingly) comply with the law.