Large cash deposits and withdrawals
Which scenario looks at the large cash itself, not only the report it produces, and does it compare the amount with what the customer is known for?
A scenario that places here
example"Large cash deposits over 15,000 in a single day"
Channels it applies to
1 of the 20 in the dictionaryCSH
Cash, branch and ATM: one sector each on the coverage chart, hatched where no scenario reaches it.
Reference lines
held figures- BSA BSA-AML-10 names USD 10,000 for the currency transaction report on cash, branch and ATM. A scenario of this typology starting above it is flagged "above the reporting threshold".
- AUSTRAC AMLCTF-43 names A$10,000 for the threshold transaction report on cash, branch and ATM. A scenario of this typology starting above it is flagged "above the reporting threshold".
Obligations
3 regimes| Regime | Obligation |
|---|---|
| Bank Secrecy Act and its regulations (31 CFR Chapter X) | BSA BSA-AML-15 Transaction Monitoring · BSA BSA-AML-10 Currency Transaction Reporting (CTR) |
| FATF 40 Recommendations | FATF R.10 Customer due diligence |
| Anti-Money Laundering and Counter-Terrorism Financing Act (Australia) | AUSTRAC AMLCTF-PartA-TxnMon Transaction Monitoring · AUSTRAC AMLCTF-43 Threshold Transaction Reports (TTRs) |
The obligations, quoted
BSA BSA-AML-15 Transaction MonitoringAutomated and manual transaction monitoring shall identify unusual or suspicious activity using risk-based scenarios and thresholds.
Where programmes usually fall short: No model validation; Scenarios not aligned to risk assessment
Source: Bank Secrecy Act and its regulations (31 CFR Chapter X)
BSA BSA-AML-10 Currency Transaction Reporting (CTR)Cash transactions over USD 10,000 in a single business day involving the same person shall be reported on FinCEN Form 112 within 15 days.
Where programmes usually fall short: No aggregation across branches; Late filings
Source: Bank Secrecy Act and its regulations (31 CFR Chapter X)
FATF R.10 Customer due diligenceFinancial institutions may not keep anonymous accounts or accounts in obviously fictitious names and must, by a principle set out in law, undertake customer due diligence when establishing a business relationship, carrying out an occasional transaction above USD or EUR 15,000 or a payment or value transfer covered by INR.16, when money laundering or terrorist financing is suspected, or when they doubt previously obtained identification data: identify and verify the customer from reliable independent sources; identify the beneficial owner and take reasonable measures to verify that identity, understanding the ownership and control structure of legal persons and arrangements; understand and where appropriate obtain information on the purpose and intended nature of the relationship; and conduct ongoing due diligence and transaction scrutiny consistent with the customer's profile including, where necessary, the source of funds. The extent of each measure follows a risk-based approach; verification takes place before or during establishment of the relationship, or as soon as reasonably practicable after it where risks are managed and business would otherwise be interrupted; an institution that cannot complete CDD does not open the account or perform the transaction, or terminates the relationship, and considers a suspicious transaction report; the requirements apply to new customers and, on materiality and risk, to existing ones. The Interpretive Note sets the risk-based approach, enhanced and simplified measures, the specific measures for legal persons, arrangements and beneficiaries of life insurance, reliance on prior verification and the timing rules.
Where programmes usually fall short: Beneficial owner identified but never verified; Ownership and control structure of corporate customers not understood
Source: FATF 40 Recommendations
AUSTRAC AMLCTF-PartA-TxnMon Transaction MonitoringSystems and controls for monitoring customer transactions for unusual or suspicious activity.
Where programmes usually fall short: No transaction monitoring
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)
AUSTRAC AMLCTF-43 Threshold Transaction Reports (TTRs)Cash transactions of A$10,000 or more (or foreign currency equivalent) must be reported within 10 business days after the transaction date.
Where programmes usually fall short: Threshold transactions not reported
Source: Anti-Money Laundering and Counter-Terrorism Financing Act (Australia)