AML Transaction Monitoring - When do you flag a 'smurfing' pattern?

asked by u/karim.karimi · 5d · 1 answers

I'm still wrapping my head around AML and specifically transaction monitoring for potential smurfing. I get the basic concept of structuring deposits to avoid reporting thresholds. But in practice, especially with high-volume accounts, when do multiple smaller, seemingly unrelated deposits start looking like a pattern you'd actually flag for further review? Is there a common number of transactions or cumulative amount within a timeframe, or is it more about the source of funds and the account holder's typical activity? What's your internal threshold or the red flag that makes you dig deeper on this particular pattern, aside from just hitting the CTR mark?

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  • u/pmarinescu· 1 pts· 5d

    You're looking for a hard number that doesn't really exist in practice. It's less about a specific count of transactions and more about the context and the deviation from a client's established behavior profile. If an account suddenly starts receiving frequent, slightly below-threshold deposits from various new sources, that's more suspicious than an existing business account doing the same thing as part of its normal operations.

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