The act of splitting cash deposits or withdrawals to avoid a CTR is known as

• A. SAR
• B. CTR
• C. KYC
• D. OFAC

Answer: (B)

Currency Transaction Reports are the mechanism banks use to document large cash activities. Splitting deposits or withdrawals to stay under the reporting threshold is a tactic often seen in attempts to avoid triggering that reporting. The idea being tested is how the reporting framework governs these transactions and the role the CTR plays in capturing the underlying activity that the structuring attempt is trying to hide. The other terms relate to different AML tools: a Suspicious Activity Report is about patterns that look suspicious, Know Your Customer concerns identity and risk on onboarding, and OFAC relates to sanctions screening. Thus, the reporting mechanism involved here is the Currency Transaction Report.