Which of the following is NOT an example of a layering transaction?

Layering serves as a crucial stage in the money laundering process, where illicit funds are obscured through complex transactions to make tracing back to their original source more challenging. The correct answer indicates a scenario that does not align with the layering process.

In this case, making a cash deposit of $9,500 to avoid the necessity of a Currency Transaction Report (CTR) is a strategy aimed at bypassing regulatory scrutiny rather than obscuring the sources of funds through complex transactions. This is more indicative of an attempt at placement, where the individual is trying to introduce illicit money into the financial system in a way that avoids detection due to the reporting requirements for transactions over $10,000.

In contrast, changing the currency or transferring funds across different accounts and countries represents typical layering activities. These actions systematically obscure the paper trail and complicate the tracking of the origins of the funds, making it difficult to identify their source. Bank-to-bank transfers also exemplify layering, especially when they involve multiple institutions or jurisdictions, further enhancing the complexity of tracing the money.

Thus, option D correctly identifies a situation that reflects placement rather than layering, distinguishing it from the other choices which embody the characteristics of the layering phase of money laundering.