"I'd like to deposit $9,800 today. Can you split it — $4,900 in my personal account and $4,900 in my business account?"
🏦
You — Teller
This is Marcus's third visit this week. Tuesday: $9,500. Thursday: $9,200. Today: $9,800 split across two accounts.
What should you do?
A
Process both deposits — the total is under $10,000, so no report is needed.
B
Refuse the transaction and ask Marcus to leave.
C
Process the transaction normally, then file a Suspicious Activity Report (SAR) — this pattern may indicate structuring.
D
Ask Marcus directly if he's trying to avoid the reporting threshold.
✓ Correct — +50 XP
Structuring — deliberately splitting transactions to stay under $10,000 — is a federal offense. Complete the transaction normally (refusing tips off the suspect), then file a SAR immediately. Never confront the customer directly.
✗ Not quite
Scenario 02 of 03
LOAN OFFICER
👩
Patricia Lin — New Business Client
"I need to move $85,000 from my new LLC to three different personal accounts — my cousin, sister, and neighbor. They helped with startup costs and I want to pay them all back today."
💼
You — Loan Officer
The LLC was opened 3 weeks ago. No invoices or contracts have been provided. The three recipients have no known business connection to the company.
How do you handle this?
A
Process the transfers — the client has explained the reason and you don't want to offend a new customer.
B
Request supporting documentation, escalate to compliance, and hold the transaction pending review.
C
Immediately close the account and report her to authorities yourself.
D
Suggest she split the transfers into smaller amounts over several days.
✓ Correct — +50 XP
Large transfers to unrelated third parties from a newly opened business account with no documentation is a classic money laundering red flag. Request supporting docs, escalate to compliance, and hold the transaction. You are not accusing the client — you are following required due diligence.
✗ Not quite
Scenario 03 of 03
RELATIONSHIP MANAGER
👨💼
Your Colleague — Private Banking
"My client wants to move $2M offshore today. He's been with us 15 years, no issues ever. He's asking us to skip the enhanced due diligence — says he's in a hurry and finds it insulting."
⚖️
You — Relationship Manager
Enhanced Due Diligence (EDD) is mandatory for transactions over $1M under AML regulations. It is not discretionary regardless of relationship history.
What do you advise your colleague?
A
Support bypassing EDD — 15 years with no issues is sufficient justification.
B
Suggest the client split the transfer into two amounts under $1M to avoid triggering EDD.
C
Advise that EDD is mandatory and non-negotiable, explain this professionally to the client, and escalate to compliance if he refuses.
D
Tell your colleague to report it to compliance and say nothing more to the client.
✓ Correct — +50 XP
EDD is a legal requirement — not a judgment call. Long-standing client relationships do not override compliance law. Explain this clearly and professionally: this is bank policy and regulatory requirement, not a reflection of distrust. If the client refuses, escalate immediately.
✗ Not quite
🛡️
Module complete!
Key takeaways from this module
✓ Always process suspicious transactions normally before filing a SAR ✓ Request documentation when transfers lack business justification ✓ EDD requirements are non-negotiable regardless of client history ✓ When in doubt, escalate to compliance — it's always the right call
Portfolio demo — Elizabeth Link · Meridian Bank eLearning