Yes, absolutely.
We are seized with the question not of whether a transaction is above or below $10,000, but rather whether it is suspicious. That goes to a profound set of guidelines to reporting entities regarding what they should consider to be suspicious, based on their knowledge of their client. I would offer the committee that we focus not specifically on $10,000 plus or minus, but rather on the pattern of transactions that would raise concerns. That question of being ever-more precise and practical and tangible in the guidance we give to reporting entities is something that we're seized with.
With regard to the question of structured transactions that are meant to fall below the radar, below $10,000, we also have advice in our paper that would give us better tools to identify efforts to go below the threshold. The term for this is “smurfing” when someone takes a large transaction and turns it into a series of small transactions that would evade the objectives of the act.
Yes, we want to focus on the suspect transactions more so than on the amount. Yes, we also want to make sure that we're not creating blind spots with that threshold, but it's a question of magnitude.