Wednesday, December 18, 2013

Other BSA Prosecutions -- CTR Plea by Former FBI Special Agent (12/18/13)

Here is another facet of the Bank Secrecy Act, this time involving its currency transaction reporting ("CTR") requirements.  A former FBI special agent, Travis Raymond Wilson, has pled to a CTR charge.  Key excerpts from the press release are:
Travis Raymond Wilson, 38, of Huntington Beach, pleaded guilty today to structuring financial transactions in violation of the federal Bank Secrecy Act,United States Attorney Benjamin B. Wagner announced. 
The Bank Secrecy Act requires financial institutions, such as banks, to file Currency Transaction Reports (CTRs) on any cash transaction that is greater than $10,000. CTRs are filed with the U.S. Department of Treasury and are made available to law enforcement agencies, such as the Federal Bureau of Investigation. It is a federal crime to make cash deposits in an amount of $10,000 or less with the intent to prevent a financial institution from filing CTRs, such transactions are known as structuring. 
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Between January 2008 and February 2013, Wilson regularly gambled at casinos in California, Nevada, Arizona, and West Virginia. Even though he frequently left the Casinos with more than $10,000 cash, Wilson regularly made deposits in amounts of $10,000 or less into his bank account. Wilson structured his cash deposits to attempt to prevent CTRs from being filed because he did want not the FBI to become aware of his gambling activities. In total, Wilson structured more than $488,000 in cash into his bank account. 
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Wilson faces a maximum statutory penalty of five years in prison and a $250,000 fine. The actual sentence, however, will be determined at the discretion of the court after consideration of any applicable statutory factors and the Federal Sentencing Guidelines, which take into account a number of variables.

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