Understanding CTR Exemptions and their Practicality

By Mohamed Aziz | September 26, 2019
Financial Institutions (FI) file Currency Transaction Reports (CTRs) which enable law enforcement to monitor and investigate potentially suspicious activity. CTRs act as a paper trail for cash transactions, and are filled out by bank personnel for each deposit, withdrawal, currency exchange or other payment or transfer greater than $10,000 in currency. In turn, the Financial Crimes Enforcement Network (FinCEN), a branch of the U.S. Treasury, reviews and correlates the customer and transaction data, and maintains a database of all filings. Nearly 50 years ago, CTRs came into existence under the Bank Secrecy Act (BSA), which established program, recordkeeping, and reporting requirements for FIs. Since then, the CTR form has been modernized several times to streamline and simplify submission requirements, and an electronic filing requirement for all CTRs was instituted. Beginning in the 1990s, FinCEN sought to reduce unnecessary regulatory burdens on filers and eliminate items which are of limited value to law enforcement. To reduce information collection, criteria were established to exempt transactions from CTR reports by certain entities.

Overcoming common challenges when updating risk assessment

By Mohamed Aziz | July 12, 2019
This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of the AML community and providing an introduction to key topics for those new to the subject. An Enterprise Wide Risk Assessment (“EWRA”) enables Financial Institutions (“FI”) to assess their BSA / AML risk profile, incorporate appropriate risk management processes, and maintain adequate controls to mitigate risk. Moreover, the Federal Financial Institutions Examination Council (“FFIEC”) requires all FIs to maintain an EWRA. Management is responsible for communicating the EWRA to the Board of Directors. The Board, in turn, is required to ensure that the FI has adequate resources both human and technological to address the identified risk areas.
1

Podcasts

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss FinCEN’s Advanced Notice of Proposed...

In this edition of AML Conversations, AML RightSource Vice Chairman John Byrne sits down with terrorist financing career expert Dennis Lormel to...

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the anniversary of the attacks on 9/11...

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the recent press release published by...

In this episode of AML Conversations, Chuck Taylor, Executive Vice President and head of Financial Crimes Advisory and Tim White, Special Advisor...

There are many transaction monitoring systems in use at financial services companies (FIs). Many of them are rules based. They apply rules to...

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss recent guidance by financial...

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the arrest of Steve Bannon and three...

In this episode of AML Conversations, AML RightSource Vice Chairman John Byrne sits down with Megan Hodge, Executive Compliance Director, BSA/AML...

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the announced seizure by the Justice...

Press

To support company growth, AML RightSource recently designed and opened an office in Highland Hills, OH. The newly renovated 43,602 square foot space...

CLEVELAND, Ohio – February 10, 2020 – AML RightSource, a leading firm focused on fighting financial crime for its clients and the world, today...

AML RightSource, a leading firm solely focused on Anti-Money Laundering (AML)/Bank Secrecy Act (BSA) and financial crimes compliance solutions, today...

AML RightSource, a leading firm solely focused on Anti-Money Laundering (AML)/Bank Secrecy Act (BSA) and financial crimes compliance solutions, today...

Our Advisory Board member Rick Small, and AML RightSource Vice Chairman John Byrne have led a multi-year effort resulting in the “Consortium for...

AML RightSource is pleased to announce the formation of its Inaugural Advisory Board to convene semi-annually starting in the first quarter of 2019.

Company’s Expansion into New York State Will Create 100 jobs in Western New York

AML RightSource is pleased to announce Timothy White, CAMS has joined the company as Vice President of Business Development and Sanctions.

AML/BSA Compliance Veteran to Expand Company’s Financial Crimes and Compliance Operations

AML RightSource, national leader in anti-money laundering services and premier provider to the financial services sector, celebrates a period of...