Latam Games: Split Cash Deposits and Corporate Responsibility

The Latam Games structuring case concerned corporate officers breaking up cash deposits to evade bank reporting requirements, conduct the company admitted in its guilty plea. According to the Justice Department’s account of the plea agreement, the Miami company split deposits across Florida, California and New Jersey between March and June 2013.

Latam Games, LLC pleaded guilty on December 6, 2018. The Drug Enforcement Administration and IRS-Criminal Investigation investigated the case. The company used banks to take its cash while deliberately evading the reports that give investigators a view of those transactions.

What Are Some Examples of Cash Structuring?

Latam Games provides a concrete example of cash structuring through repeated deposits on consecutive days. In the plea agreement described by the Justice Department, the company admitted that its officers divided cash into smaller deposits to avoid currency reports.

The March sequence was $4,240 on March 18, 2013, $7,445 on March 19 and $9,560 on March 20. The following month, the company deposited $9,045 on April 25 and $9,000 the next day.

Those examples sit within the broader March-to-June activity described in the plea. The company admitted a willful pattern involving more than $100,000 in a twelve-month period.

The amounts varied, and some sat well below the reporting line. Looking only for deposits just short of that line would miss part of this admitted pattern.

Cash Reporting and Deposits Across Consecutive Days

The reporting rule Latam Games sought to evade requires banks to report currency transactions of more than $10,000. The currency-reporting rules also require a bank to combine cash transactions it knows are by or for the same person during a business day, counting cash in and cash out separately.

The bank’s aggregation rule looks at a business day. Latam Games’ guilty plea described a pattern across days: officers deliberately divided deposits to avoid the reporting system, with the published examples extending across consecutive days.

The Bank Secrecy Act makes financial institutions part of the information system investigators use. The Wharton paper discussed below describes its paired obligations: keeping records of customer accounts and transactions, and affirmatively reporting covered cash activity. A bank holding a record and the government receiving a report serve different parts of that system. Latam Games’ officers targeted the reporting part by dividing the cash before depositing it.

Why Structuring Defeats the Reporting System

Splitting deposits attacks a reporting system built around transaction amounts. The Wharton Initiative on Financial Policy and Regulation’s 2024 paper, Anti-Money Laundering: Opportunities for Improvement, explains how reporting evasion prompted lawmakers to respond:

The paper also describes stronger bank internal controls as part of that response. Congress addressed the customer’s deliberate splitting of transactions as well as the bank’s ability to meet its reporting duties. That pairing helps explain why the Latam Games story turns on officers’ decisions before the deposits reached a bank.

Corporate Responsibility in the Guilty Plea

Latam Games’ cash structuring guilty plea concerned corporate deposits directed by its officers. The company’s admission connected the people controlling the deposits to the purpose of avoiding reports. The officers made the decisions, and Latam Games admitted the conduct as the company’s own.

That is the part an insider can explain. A deposit record gives an amount and a date. Someone involved in cash handling may also know who chose the amount, who directed when it should reach the bank and what explanation accompanied those instructions. We look at how those pieces fit together when evaluating a suspected structuring pattern.

What an Insider Can Add to the Deposit Trail

The company and the bank offer different views of a deposit trail. Someone preparing company deposits may know how the cash was divided before it arrived at a branch. Someone reviewing bank account activity may see the dates, amounts and connections among transactions. Our work brings the account of the decision together with the account of the money.

Your view may come from preparing deposits, reconciling company cash or reviewing the account activity. We work with you to establish what you saw directly and how it connects to the company’s records.

Our whistleblower experts assess which program fits the conduct your information can establish, including FinCEN’s program for Bank Secrecy Act enforcement. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. These are separate programs, and we work through the choice with you, bringing in whistleblower lawyers with the expertise your case needs.

You Know Who Directed the Deposits

If you know why a company’s cash was divided before it reached the bank, speak to our whistleblower experts about the instructions behind the deposits. We connect your knowledge of the business to the transaction evidence, bring in money laundering whistleblower lawyers who understand reporting-evasion cases, and stay alongside you to build your strongest money laundering whistleblower case.