IRS Criminal Investigation Division Announces New Policy on Structuring Cases
The IRS has recently issued a new policy relating to civil forfeiture in structuring cases. Structuring is the practice of executing financial transactions in a pattern calculated to avoid the creation of certain records or reports. Pursuant to 31 CFR §103.22, financial institutions are required to report each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000. When an individual or business deposits or withdraws more than $10,000 in currency through a financial institution, the institution files a currency transaction report (CTR). CTRs are used by the government as a way to verify income and to catch individuals engaged in illegal transactions and money laundering.