Depositing physical currency into one or multiple financial institution accounts is a primary placement tactic for introducing illicit proceeds into the formal banking system. Criminals frequently split or stagger these deposits into amounts just below regulatory reporting thresholds, sometimes leveraging third-party depositors who make multiple drop-offs across different branches in quick succession. In one reported instance, over 60 individual deposits were made into a single account over a six-week period, with amounts ranging from a few thousand to well over one hundred thousand dollars—raising suspicion due to the rapid and repetitive volume. Perpetrators may also set up or use multiple accounts to obscure the origin and flow of funds, transferring between them to further complicate detection efforts. Typical red flags include unusually large or repetitive deposits that exceed a customer’s stated income, deposits made under known threshold values, and reluctance or inability to explain fund sources. These structured cash deposits often transition quickly into layering schemes when combined with further transfers, particularly if done at multiple institutions or via additional services.
Cash Deposits
Physical Currency Deposits
Cash Lodgements
Depósitos En Efectivo
Tactics
Cash deposits are a primary method for introducing illicit funds into the formal banking system, often by structuring deposits just below reporting thresholds. This technique reduces the immediate detection risk by merging criminal proceeds with legitimate accounts at the earliest stage of laundering.
Risks
This technique exploits the inherent vulnerability of deposit accounts that accept physical cash with limited oversight. Criminals structure or stagger deposits below regulatory thresholds, making it more difficult for institutions to detect illicit proceeds when monitoring product usage alone.
Criminals exploit in-person deposit channels—such as branch counters, ATMs, or multiple third-party depositors—to spread out cash drop-offs. They circumvent detection by splitting deposits across different locations or account holders in quick succession.
Indicators
Frequent cash deposits in a short timeframe across multiple accounts held by the same customer without a clear legitimate rationale.
Large cash deposits that significantly exceed the account's typical activity or declared income level.
Cash deposits structured in amounts just below mandatory reporting thresholds.
Customer profiles show a discrepancy between declared income and the frequency or volume of cash deposits, identified during due diligence.
Deposits characterized by round figures or repetitive amounts, lacking a clear legitimate rationale.
Use of multiple accounts by a single customer to receive cash deposits without a clear legitimate business rationale.
Reluctance or inability of a customer to provide a credible explanation for large cash deposits during standard due diligence or account interactions.
Frequent cash deposits by third-party individuals into the same account, lacking a credible explanation of their relationship to the account holder.
Data Sources
- Documents comprehensive account actions, including deposits, transfers, and user-initiated changes in real-time.
- Pinpoints suspicious deposit timing or repetitive deposit actions across multiple accounts or branches.
- Assists in reconstructing the sequence of placement steps when investigating layered cash flows.
- Provides detailed records of deposit timestamps, amounts, and transaction references for each account.
- Enables detection of recurring deposit patterns, sub-threshold structuring, and unusually high deposit frequencies inconsistent with stated customer profiles.
- Supports cross-checking deposit sources to identify potential third-party or multi-location deposit behaviors.
- Shows account ownership, type, balances, and historical deposit patterns for each customer.
- Enables detection of multiple accounts used to distribute or layer funds, revealing structured placements.
- Helps identify rapid inflows not aligned with normal account activity or stated financial circumstances.
- Contains declared income, source of funds, beneficial ownership information, and overall risk profile of customers.
- Facilitates comparison of stated financial capacity against large or frequent cash deposits, flagging potential inconsistencies.
- Provides essential background to investigate the legitimacy of deposit activity and identify hidden relationships or beneficial owners.
- Tracks precise ATM deposit details (e.g., date, time, amount) and geolocation of deposit activities, enabling the identification of repetitive or structured cash deposits across different ATM locations.
- Helps detect sub-threshold deposit patterns, such as frequent or staged deposits in quick succession, which are indicative of potential structuring.
- Assists investigators in correlating deposit behavior with customer profile data to pinpoint anomalies in cash deposit volumes or frequencies.
Mitigations
Require additional source-of-funds verification for customers who deposit unusually high volumes of cash or exhibit patterns inconsistent with their known profile. Obtain supporting documentation, such as pay stubs or tax records, and enforce stricter ongoing monitoring or lower deposit limits as warranted by risk findings.
Collect and verify detailed customer information during onboarding, including all authorized depositors and their relationships to the primary account holder. Corroborate stated income or business activities with expected cash deposit levels, and reject or query unsubstantiated large cash inflows.
Implement rules-based or advanced analytics to specifically target repetitive small or structured cash deposits below regulatory thresholds, multiple deposits across different branches or accounts in a short timeframe, or deposit patterns that conflict with a customer’s stated income. Escalate alerts promptly for investigation to confirm legitimate sources of funds.
Systematically report cash deposits that meet or exceed defined regulatory thresholds. Implement internal controls to track aggregated deposits from a single customer over a specified period, flagging potential structuring attempts involving numerous smaller transactions designed to evade Currency Transaction Report (CTR) requirements.
Continuously review customer accounts for changes in deposit frequency, volume, or patterns. Compare actual deposit activity against the customer’s claimed profile, requiring plausibility checks or documentation for cash amounts that significantly exceed stated sources of income or business scale.
Instruments
- Perpetrators open or misuse existing bank accounts to receive frequent structured cash deposits.
- By dispersing deposits across multiple branches or accounts, criminals obscure the funds' true origin and circumvent detection triggers such as large-sum reports.
- Subsequent intra-account transfers further complicate the audit trail, assisting in layering the illicit funds.
- Criminals physically deposit banknotes and coins, splitting or staggering amounts below reporting thresholds to avoid detection.
- The anonymity, portability, and immediate liquidity of physical currency make it an ideal instrument for introducing illicit proceeds into the banking system through repeated small placements.
Service & Products
- Enables direct physical deposits of currency at bank counters, ATMs, or other deposit points.
- Criminals exploit daily or transaction limits by depositing multiple times across branches, thereby dispersing significant amounts of illicit cash.
- Criminals deposit illicit cash into business accounts, presenting it as legitimate revenue to lessen scrutiny.
- They may split deposits below reporting thresholds across different accounts or branches, obscuring the total amounts introduced.
- Criminals use personal checking accounts to place illicit cash in smaller, repeated amounts, avoiding regulatory triggers.
- Third-party depositors may also contribute funds into these accounts, masking the true origin of the money.
Actors
Illicit operators deposit physical currency into financial institution accounts, splitting or staggering deposits below reporting thresholds. They may direct third-party depositors to make multiple small drop-offs, obscuring the funds’ true origin.
This practice complicates financial institutions' due diligence and monitoring processes, as individually small transactions can appear routine while collectively representing significant illicit proceeds.
Money mules act as third-party depositors, physically placing cash into various accounts on behalf of illicit operators. They often structure repeated deposits below regulatory thresholds across multiple branches in quick succession.
This tactic fragments the deposit pattern, making it more difficult for financial institutions to detect the aggregated flow of illicit funds.
Criminals exploit cash-intensive businesses by depositing illicit funds under the guise of routine revenue. Repetitive cash deposits remain plausible for such enterprises, reducing immediate suspicion.
Financial institutions struggle to distinguish genuine daily takings from laundered money, especially when deposits are kept below reporting triggers and are structured across different accounts or branches.
References
AUSTRAC (Australian Transaction Reports and Analysis Centre) . (2013). Typologies and case studies report 2013. AUSTRAC. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/typologies-and-case-studies-report-2013
AUSTRAC (Australian Transaction Reports and Analysis Centre). (2014). AUSTRAC typologies and case studies report 2014. Commonwealth of Australia . http://www.austrac.gov.https://www.austrac.gov.au/sites/default/files/2019-07/typologies-report-2014.pdf