United States v. Daniel F. Aversa, United States of America v. Vincent Mento, United States of America v. William J. Donovan

OPINIONS EN BANC

SELYA, Circuit Judge.

The government charged each of these appellants with criminal violations of the Bank Records and Foreign Transactions Act (BRFTA), Pub.L. No. 91-508, 84 Stat. 1114 (1970) (codified as amended in various sections of 12 U.S.C., 15 U.S.C., and 31 U.S.C.). Appellant Donovan was charged with, and convicted of, failure to file currency transaction reports (CTRs). See 31 U.S.C. § 5313 (1988). Appellants Aversa and Mentó were charged with, and convicted of, structuring bank deposits to avoid triggering currency transaction reporting requirements. See 31 U.S.C. §…