Evan Bobzin, a 39-year-old resident of Chester, Connecticut, was sentenced in federal court to 24 months in prison for embezzling nearly $2 million from his employer, Hoffman's Gun Center in Newington.
Bobzin's illicit activities began in 2016, continuing through 2023, while he held the position of head of information technology at the business. Court documents indicate that he repeatedly accessed the store's front office safe after disabling security cameras, stole cash from daily receipts, and deposited the proceeds into his personal accounts.
Over seven years, Bobzin made 287 deposits totaling approximately $1.9 million and purchased cashier's checks with an additional $161,330 of the stolen funds.
Prosecutors detailed that Bobzin structured his financial transactions to avoid triggering bank reporting requirements, frequently depositing sums below the $10,000 threshold and shifting his banking practices after being flagged for suspicious activity in 2022. In addition to the theft, Bobzin committed tax fraud by failing to disclose the embezzled funds on his annual returns from 2016 through 2022, resulting in a tax loss to the federal government of $436,178. For instance, in 2020, his reported income was only $9,914, omitting more than $432,000 in stolen cash.
Source: https://www.shorenewsnetwork.com/2024/11/30/connecticut-man-sentenced-to-2-years-in-prison-for-2-million-embezzlement-scheme/
Commentary
In the above matter, the convicted employee tried not to trigger bank reporting requirements.
Bank reporting requirements, particularly those established under the Bank Secrecy Act (BSA), mandate that financial institutions monitor for, and report, certain types of suspicious activity, including large cash transactions and activities potentially linked to illegal conduct.
One of the most well-known requirements is the obligation to file a Suspicious Activity Report (SAR) for transactions that aggregate at least $5,000 and appear to involve funds derived from unlawful activity, or that are structured to evade federal regulations. Institutions must file a SAR within 30 days of detecting suspicious activity, with an additional extension of up to 60 days if more time is needed to identify suspects. The intent of these rules is to create a traceable record of financial activity that law enforcement can use to prevent and prosecute crimes such as money laundering, fraud, and embezzlement.
Embezzlers and other criminals try to avoid triggering these reporting requirements because a SAR or Currency Transaction Report (CTR) draws immediate scrutiny from financial regulators and law enforcement. One of the most common strategies for evading detection is "structuring," in which an individual breaks up large sums of cash into smaller deposits below established reporting thresholds, such as $10,000, to avoid automatic generation of reports by the bank.
These efforts are designed to escape both the transactional "paper trail" and the attention of compliance departments, which could lead to the discovery of underlying criminal activity. The regulatory framework specifically criminalizes not just the predicate crimes such as embezzlement or money laundering, but also the act of structuring transactions to circumvent reporting mandates.
Signs that someone may be attempting to avoid bank reporting requirements include frequent cash deposits or withdrawals just below the $10,000 threshold, regular transactions that seem inconsistent with the customer's stated level or type of business activity, or sudden changes in banking patterns, such as opening multiple accounts to distribute deposits. Banks are trained to monitor for these behaviors and, if detected, are required to file a SAR, which then becomes part of a broader effort by law enforcement agencies to analyze trends and pursue potential criminal investigations.
Source: https://www.law.cornell.edu/cfr/text/31/1020.320
