Pro Tier Module
AML Transaction Threshold Monitor
Bright-line BSA/FinCEN reporting rules applied by exact arithmetic, every flag cited to its CFR section.
See it run - a worked example, 100% in this browser tab
The problem
BSA/AML analysts at MSBs, banks, and casinos must apply CTR, structuring, and SAR reporting rules across transaction sets where a single missed aggregation or stale threshold can mean a regulatory finding. Spreadsheets drift and rarely cite the rule that triggered a flag.
The local-first solution
This plugin applies the bright-line Bank Secrecy Act reporting rules entirely in your browser using exact integer-cent arithmetic and exact calendar-day grouping, with every flag citing the controlling statute or CFR section and no transaction data leaving the device.
What it does
CTR aggregation: cash-in and cash-out summed separately per person per business day, flagging buckets over the threshold (31 CFR 1010.313)
Structuring aggregate-evasion flag: same-direction currency over a rolling N-business-day window that sums past the CTR total with no single day crossing it
Structuring just-under pattern flag: repeated same-direction cash in the confirmable just-under band (smurfing signature)
SAR-consideration prompts where a transaction or aggregation reaches the SAR floor and is marked suspect
Exact integer-cent summation with no binary-float drift, plus exact business-day grouping
Every flag carries the rule, citation, and an audit trail
Honest scope
Not legal advice and not a determination of illegality or of a filing duty: output is a set of review flags with rule, citation, and audit trail that a qualified BSA/AML officer acts on. The arithmetic and day-grouping are exact; the dollar thresholds and structuring window are dated regulatory inputs you confirm, and SAR subjective suspicion, MSB-specific floors, CMIR, FBAR, Form 8300, OFAC screening, and exempt-person designations are flagged as out of scope, not computed.
Authorities cited
- 31 U.S.C. 5313 - Reports on domestic currency transactions: the statutory basis for the Currency Transaction Report (CTR) requirement.
- 31 CFR 1010.311 - A financial institution must file a CTR (FinCEN Form 112) for each deposit, withdrawal, exchange of currency, or other payment or transfer in currency of more than $10,000.
- 31 CFR 1010.313(b) - Aggregation: multiple currency transactions are treated as a single transaction if the institution has knowledge they are by or on behalf of the same person and total more than $10,000 in currency during any one business day (cash in and cash out aggregated separately).
- 31 U.S.C. 5324 - Structuring transactions to evade the reporting requirements is unlawful; it prohibits structuring, assisting in structuring, or attempting to structure a transaction for the purpose of evading the CTR requirement.
- 31 CFR 1010.314 - Structuring is prohibited; no person shall structure or attempt to structure any transaction to evade the reporting requirements.
- 31 CFR 1020.320 - Suspicious Activity Report (SAR) by banks: a SAR (FinCEN Form 111) is required for a transaction conducted or attempted by, at, or through the bank that involves or aggregates at least $5,000 in funds or other assets and that the bank knows, suspects, or has reason to suspect is suspicious.
- 31 U.S.C. 5318(g) - Statutory reporting of suspicious transactions (the SAR authority) and the safe harbor for institutions that report.
- FinCEN Form 112 (CTR) and FinCEN Form 111 (SAR) - the BSA E-Filing reports referenced by the rules above.
- FinCEN Advisory / FIN-2012 guidance on structuring ("smurfing") - same-person currency broken into sub-$10,000 amounts to evade the CTR; intent is the legal element (a determination this tool does not make).
Screen a transaction set
Run the monitor in your browser and route the flagged buckets into a Sandbox workspace, a Worklog case file, or a Gate client portal. Nothing is uploaded to anyone's cloud.