FinCEN recently highlighted the work of a financial institution that involved Suspicious Activity Reporting and Currency Transaction Reporting as it pertains to true beneficiaries.
In this case, the bad actors recruited heroin addicts to steal certain types of goods from stores in the Chicago area. They exchanged their stolen goods for cash from small stores operated by the criminal group. The suspects worked through numerous financial institutions, structured cash deposits and withdrawals through a combination of business and personal accounts, and would vary their method of conducting transactions, sometimes taking them to the teller window, sometimes taking them to ATMs.
