ATM Structuring

Frequent, sub-threshold ATM deposits systematically introduce illicit cash into the financial system, effectively completing the initial infiltration of criminal proceeds while reducing the immediate risk of detection.

Criminals exploit deposit-taking ATM channels by structuring frequent, sub-threshold cash deposits, leveraging the self-service nature of ATMs to avoid the tighter scrutiny normally associated with in-person branch transactions. This lack of face-to-face oversight is the primary vulnerability enabling launderers to remain under reporting thresholds and evade detection.

• Provides detailed records of all deposits, withdrawals, timestamps, and amounts, enabling investigators to identify frequent, low-value ATM transactions that aggregate just below reporting thresholds.
• Allows cross-referencing with account data to confirm whether multiple individuals (smurfs) are depositing into the same account, thus revealing potentially structured deposits under threshold limits.
• Facilitates pattern analysis of repeated amounts and deposit intervals to detect suspected ATM structuring schemes.

• Contains verified customer profiles, declared sources of funds, and expected transaction behaviors, which can be compared against frequent sub-threshold ATM deposits.
• Enables identification of deviations from the customer’s financial profile, revealing red flags when ATM usage and deposit volumes exceed or contradict stated activity.
• Supports more thorough investigation of unusual account activity by linking customer risk assessments to emerging structuring indicators.

• Captures the specific ATMs used, including exact locations, timestamps, and deposit amounts, helping to confirm sub-threshold patterns across different machines.
• Enables analysis of transaction clustering in certain geographic regions or unusual ATM activity outside the customer’s typical area.
• Assists in linking multiple depositors (smurfs) using various ATMs to structure funds undetected by traditional branch-based monitoring.

• Incorporates location-based records of financial transactions, allowing direct comparison of the customer’s usual regions of economic activity against sudden or widespread ATM deposits in multiple areas.
• Flags anomalies where deposit volumes and geographic dispersion deviate significantly from established norms, indicating possible structuring activities.
• Aids in assessing whether ATM-related transactions are suspicious based on mapped proximity or cross-regional patterns without a legitimate business rationale.

Configure detection scenarios specifically targeting repeated, sub-threshold ATM deposits within short intervals or across multiple geographic locations. Aggregate daily totals to highlight potential structuring attempts that individually stay below regulatory reporting limits, generating real-time alerts for investigative review.

Implement automated aggregation of multiple ATM deposits within a defined timeframe for each customer. If the aggregate exceeds threshold limits, file the corresponding CTR to ensure that structuring via small increments does not evade required reporting.

Incorporate sub-threshold ATM deposit frequency and dispersion patterns into the customer risk rating framework. Accounts demonstrating frequent or geographically diverse small-value deposits are escalated for closer scrutiny, enabling timely detection of structuring tactics.

Restrict or suspend ATM deposit privileges for accounts that repeatedly engage in sub-threshold deposit patterns indicative of structuring. Require in-branch interaction or additional documentation to verify the source of funds, preventing the easy concealment of illicit cash via ATMs.

• Sub-threshold ATM deposits feed directly into a linked bank account, allowing illicit proceeds to be commingled with legitimate funds.
• Once in the account, criminals can conduct subsequent transfers or withdrawals to further obscure the transaction trail.
• The reliance on self-service ATM channels circumvents more rigorous in-person branch monitoring, aiding the layering process overall.

• Criminals deposit sub-threshold amounts of illicit physical currency through deposit-taking ATMs, avoiding direct scrutiny from bank staff.
• By splitting total illicit funds into multiple small cash deposits below reporting thresholds, they evade automated transaction monitoring alerts.
• Rapid, repeated deposits across various ATMs and times leverage the anonymity and convenience of self-service machines, making detection more difficult.

• IDMs’ advanced deposit features allow laundering of funds through frequent, low-value cash deposits.
• Real-time processing of each deposit provides quick layering opportunities, making it harder to identify suspicious patterns in aggregated transactions.
• Operating with limited direct oversight, IDMs lessen the chance of face-to-face checks that might deter or detect structuring schemes.

• Criminals repeatedly deposit or withdraw cash in small increments, keeping each transaction below reporting thresholds.
• By using multiple ATM locations and spacing out transactions, they evade aggregated monitoring that might otherwise detect large or frequent cash movements.
• Minimal in-person oversight at ATMs reduces the likelihood of immediate scrutiny, facilitating the structuring process.

Organized crime groups orchestrate ATM structuring by:

• Coordinating or funding multiple individuals (or “smurfs”) to deposit small amounts of illicit cash into ATMs.
• Ensuring each deposit remains below reporting thresholds to evade monitoring or suspicion.

This fragmentation of funds across many deposits complicates financial institutions’ detection efforts, as suspicious activity may only become evident when deposits are aggregated across different accounts or locations.

Money mules facilitate ATM structuring by:

• Physically depositing sub-threshold amounts of illicit cash into ATMs, following instructions from criminal organizers.
• Using multiple ATMs or staggering deposits to avoid detection.

By relying on individuals who appear customer-like to the bank, criminals circumvent more thorough in-person monitoring, increasing challenges for financial institutions in identifying aggregated suspicious activity across different accounts or deposit points.