My wife, a dual US/Russian citizen, has about $90k in cash in Russia that we would like to move to the U.S. Banks no longer allow transfers from Russia to the US. She travels there about 3 times a year, and brings about $9.5k of funds back to deposit into our US bank account. We have recently been warned that this could be a federal crime with serious punishments from our bank, known as “structuring”. Is there a good way to avoid and/or correct this issue? She is not allowed to bring more more than $10k out of Russia at any one time. And since it is less than $10k, she does not need to report to US customs when coming into the country. Any advice?
I’ve never heard of, and know nothing about, such a law or regulation. What did occur to me was that, if it is cash that is being brought back, not putting it in a bank would seem to preclude serious punishments from (y)our bank.
Thank you for thinking about it and your suggestion. I am not sure how to use the funds (or gain interest) without putting into a bank. I guess some could be used for groceries, rather awkwardly going back to using cash and change everywhere. But little else.
Enter your entire post into AI (e.g., ChatGPT) for a detailed warning and possible solutions. Good advice.
George
Yes, the easiest way would be to simply deposit more than $10k in cash. Banks have to file a Currency Transaction Report for any cash amount 10k or more (it is primarily to track money laundering and tax avoidance). When you deposit an amount near 10k, it looks suspicious. Do that more than once and the bank then has to file the more severe Unusual Activity Report - which might lead to the even more severe Suspicious Activity Report.
Again, easiest way to avoid all of this is just deposit more than 10k. She might be asked questions and that is OK. Better to be upfront and avoid suspicion than risk the IRS getting all up in your business. There is nothing wrong or illegal in depositing more than 10k in cash. Even if she withdraws 1k the week prior to get it to over 10k.
Thank you Hawkwin and George - both excellent pieces of advice. The Kawkwin approach certainly seems easiest. Following the advice to,
“Given the serious legal implications and the current sanctions environment, professional legal advice is essential before taking any action. The penalties for structuring and sanctions violations can be severe.”
Seems likely a costly approach. Maybe the lawyers would take cash, reducing the problem! (Just joking!)
Structuring laws are serious—breaking large deposits into smaller ones to avoid reporting can get you in real legal trouble, even unintentionally. Best approach is full transparency and proper documentation. In business, I use Phonexa to track every financial touchpoint from lead to payment, so everything’s traceable. That mindset helps keep both marketing and money above board.