CTRs and Terrorist Activities
An analysis of CTRs tied to terrorism raises some interesting facts which should be useful in your BSA program. Of the CTRs related to terrorism, 64% were for cash deposits of less than $20,000 and two thirds of those were for cash deposits of less than $15,000. Conversely, the cash out reports show very different behavior. Approximately 75% of the reported cash outs connected to terrorism were for amounts over $20,000. This information indicates that another way to analyze high risk accounts would be to compare the size of large cash deposits and withdrawals.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 13, 11/05
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