Massachusetts Structuring Plea: Business Receipts in Personal Accounts

In the Massachusetts structuring plea, the majority owner of a commercial trash collection business admitted structuring approximately $1,261,724 through separated business receipts, personal-account deposits and cash withdrawals, according to the Justice Department’s account. For someone who handles receipts or reconciles accounts, the useful question is who decided where that money went and how it came back out.

The defendant pleaded guilty on September 28, 2023. The admitted structuring covered activity during 2016 through 2020.

How Business Receipts Became a Structuring Case

In the guilty plea, the defendant admitted a pattern in which business receipts went into a personal bank account and came back out as cash.

For someone who handles business cash, the connection is practical: who directed the use of personal accounts, and who knew why the money was withdrawn? An employee familiar with the receipts may recognize the business’s money in a transaction that looks different from the bank’s side. We look at the receipts and account activity together to understand that connection.

The criminal plea also involved a tax loss.

Cash Withdrawals Are Part of the Reporting Story

Banks have to report qualifying large cash transactions, whether the cash goes in or comes out.

The Wharton Initiative on Financial Policy and Regulation’s paper Anti-Money Laundering: Opportunities for Improvement, published in 2024, describes why lawmakers addressed the practice:

The paper connects that response to stronger internal controls at banks. The point for an insider is the deliberate arrangement of transactions around reporting requirements. The account activity shows the pattern. Knowledge of the decisions behind it can explain its purpose.

What Is the Difference Between SAR and CTR?

A currency transaction report records qualifying cash movements. A suspicious activity report addresses suspected wrongdoing, including transactions a bank suspects were arranged to evade reporting.

That distinction matters when business receipts pass through personal accounts. The useful account includes both the cash movement and the explanation for the way it was arranged. An insider who understands the business can connect those parts.

What an Insider Would Recognize in the Records

The most useful view of this pattern connects the business’s receipts, the accounts receiving them and the decisions behind the cash withdrawals. Someone handling payments may recognize the receipts. An operations employee may understand account activity. A compliance officer or auditor may know how that activity was reviewed.

Bank anti-money laundering work brings those perspectives together through customer information, ongoing monitoring, internal controls and independent testing. Customer due diligence includes understanding the relationship, developing risk profiles and updating information as risks warrant. We work with you to understand what your part of the process reveals about the whole transaction trail.

The Wharton paper adds a practical observation about the channels people choose to move money. Its analysis identifies volume, detection risk, simplicity, cost and speed as reasons to favor one channel over another. It also argues that weak points in the system can attract disproportionate use. A method that moves money cheaply, quickly and with little risk of detection has an advantage over one that is harder to use. The paper argues that enforcement should focus on those weak points, where closing a gap can have an outsized effect.

That perspective makes the routine handling of receipts worth examining. The same deposit and withdrawal process can be repeated, and someone familiar with the business may understand why a particular account or cash practice was chosen. Our question is what connects the recurring transactions to the decisions behind them.

What Are Some Examples of Cash Structuring?

Cash structuring examples include divided cash deposits intended to evade reporting, repeated deposits spread across accounts and the personal-account cash withdrawals described in the Massachusetts plea. The criminal cases show different ways of arranging the cash movements around the reporting system.

In its guilty plea, Latam Games admitted structuring through cash deposits its officers divided to evade reporting. The admitted pattern involved more than $100,000 over a twelve-month period.

In the Postal Annex case, the owner admitted in a guilty plea to a pattern involving 469 cash deposits into at least 19 accounts, according to the Justice Department’s announcement. The owner also served as the designated Bank Secrecy Act and anti-money laundering officer. The person meant to catch reporting evasion was directing it.

That is why independent testing matters alongside a compliance officer, internal controls and employee training. Someone inside that process may know whether its checks reached the person directing the cash movements.

Where Whistleblower Expertise Fits

A whistleblower’s knowledge can connect transactions to the people directing them and the controls intended to catch reporting evasion. Choosing the appropriate whistleblower program depends on the conduct and the government action it supports. We assess those connections with you and bring in money laundering whistleblower lawyers who understand cash reporting and financial-institution controls.

The Financial Crimes Enforcement Network’s whistleblower program addresses covered Bank Secrecy Act and sanctions violations. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. We identify the route that fits the facts you know and stay with you through the case.

You Know Why the Cash Moved

If you can connect business receipts, personal-account deposits and cash withdrawals to the decisions behind them, talk to our whistleblower experts about the cash trail. We build your strongest case around what your position lets you see, find money laundering whistleblower lawyers who know cash-reporting cases and stay with you from the first conversation through the pursuit of a recovery.