Question & Answer

Question: We are having a few problems with the Bank Secrecy and Money Laundering rules. Can you please describe the situations where multiple transactions apply? And, in a related question, could you please tell me if savings bonds are included in the "Over $3,000 " requirements?

Answer: The last part your question is much easier than the first! No, savings bonds are not included in the "Over $3,000" requirements. The Department of the Treasury was very specific in relating exactly what had to be recorded and logged by financial institutions. Cashier's checks, traveler's checks, money orders and bank checks were all in the final rule. What may be causing some confusion is that in the proposed rule, it referred to "...or similar instruments." That was dropped from the final wording, and Treasury became very specific.

The first part of your question is more complicated. The best rule of thumb is this-if one person comes into your institution and makes deposits into one account or into many accounts, and the total cash going over the teller's window is over $10,00 in one day, you will have to file a Currency Transaction Report. If more than one person comes in, but all persons make deposits into the same account, and the deposits total over $10,00 in one day, you will have to file a CTR. We'll go into this in more detail in a future issue.

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 2, 3/91