I enjoy contemplating the nuts and bolts of these laws with respect to what exactly would be allowed and what would not.
For example, if I were to withdraw $15k every friday and re-deposit it every monday under the guise that I want it available for gambling over the weekend, that would raise a flag, but it's easily explainable. Would it be considered "structuring" if I did this for a while just to establish a pattern, or is it only structuring if you're trying to avoid triggering a report?
If the $15k occasionally didn't show up on monday, would I then need to come up with another explanation (e.g. "I lost")? Would it fly if I were actually paying this to a friend by way of intentionally losing to him in a private card room?
Structuring is withdrawing cash in under 10k increments to avoid the automatic reports that occur over 10k. You wouldn't be in trouble for structuring for withdrawing 15k every week, because you would trigger a CTR every week. More accurately twice a week if you re-deposited the cash. There is nothing inherently illegal in generating CTRs, or withdrawing cash over $10k.
You overestimate the amount of attention paid to CTRs. There are people and cash heavy businesses that trigger CTRs all the time. The reporting requirement is a fixed dollar amount that hasn't been adjusted since 1970. From a law enforcement standpoint CTRs are spam.
The way to generate attention is by trying to avoid CTRs or the equivalent rules for cashiers checks and money orders (MIL). That will get you a SAR. Those might get investigated if you generate a few of them.
Actually, based on reading that wikipedia article and the related one on "structuring", it's not clear to me that the scenario I described couldn't be argued to be structuring. The relevant quote is that you may not structure transactions "for the purpose of evading the reporting requirements of section 5313 (a) or 5325 or any regulation prescribed under any such section," and my proposed scheme is designed not to avoid the CTR but rather the Suspicious Activity Report. So I think it's arguable that they could nail me for structuring.
For example, if I were to withdraw $15k every friday and re-deposit it every monday under the guise that I want it available for gambling over the weekend, that would raise a flag, but it's easily explainable. Would it be considered "structuring" if I did this for a while just to establish a pattern, or is it only structuring if you're trying to avoid triggering a report?
If the $15k occasionally didn't show up on monday, would I then need to come up with another explanation (e.g. "I lost")? Would it fly if I were actually paying this to a friend by way of intentionally losing to him in a private card room?