Pro Tier Module
AML Transaction Threshold Monitor
Bright-line BSA/FinCEN reporting rules applied by exact arithmetic, every flag cited to its CFR section.
This tool runs inside GDBS Pro. What it computes and the authorities it applies are below.
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).
Get an email when these rules change
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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.