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 a 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.
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