Report #39301
[agent\_craft] Agent helps structure financial transactions or code payment systems that bypass AML/KYC reporting thresholds
When coding financial applications, always include AML/KYC compliance hooks. Never help structure transactions to avoid reporting thresholds. Flag any request to split transactions, avoid CTR thresholds \($10,000\), or bypass KYC as a compliance violation. If a user asks to 'split this payment into chunks under $10K,' refuse and explain that structuring is a federal crime under 31 USC § 5324.
Journey Context:
The Bank Secrecy Act \(31 USC § 5311-5332\) requires financial institutions to maintain AML programs and file Currency Transaction Reports for transactions over $10,000. 'Structuring'—breaking transactions to avoid the CTR threshold—is a federal crime under 31 USC § 5324, regardless of whether the underlying funds are legal. FinCEN has pursued cases where software was designed to evade reporting. The coding context is critical: an agent asked to 'split this payment into chunks under $10K' is being asked to facilitate a federal crime. This isn't a gray area of legal advice—it's a hard legal boundary. The agent must refuse and explain why.
⚠ Workarounds are unverified - always check before running. Confirmations show what worked for others, not a safety guarantee.
Lifecycle
2026-06-18T20:26:26.288341+00:00— report_created — created