As I know is commonplace, our large cash transaction report aggregates cash ins/outs by Tax ID numbers associated with accounts. We identify multiple deposits or withdrawals of cash benefiting a single owner using this report.

However, there are some transactions that are not being captured - specifically those where one conductor may handle business for multiple benefactors. For example, we do not capture the conductor's TIN when Person A deposits cash into Person B's and C's account (aggregate of which is over $10k) each at different branches because these show up under Person B and C on the report.

Also, any checks being cashed are not showing on the report because our tellers do not enter the conductors TIN in the online teller system.

Is this going "over and above" to think we should institute procedures to capture these other types of cash transactions. I know the regs say "when the bank is aware of an aggregate reportable amount". Maybe we should just be satisfied not knowing in these instances. I'd appreciate some feedback and maybe insight on how your shops are handing this same thing.

We had a similar issue, but for is it was mainly individuals conducting busiensses for personal and various business accounts. Before we had an automated sytem, we relied on tellers catching the mutliple deposits.

We now use AML Manager (from FiServ), which has an option to group 'related' entities. So, if we know John Doe regularly deposits cash from Doe Family Market, and Doe Property Management, plus John Doe's personal account, we can tell the system in advance. If the cash deposited on any business day at any location into the accounts we've grouped exceeds a total $10,000, we'll recieve an alert. Of course, this requires confirming with the tellers that John Doe in fact was the transactor each time, but at least we recieve an alert to start with.
The obvious shortfall is that the system can't possibly know whether this is ocurring in accounts we haven't already identified as being related somehow.

I have a report that pulls all cashed debits $3000-$10000 that I review daily. I also pull the image of the physical item to identify the transactor. I have found reportable CTRs that were not captured on the large cash transaction report.

If you have the capability to run a cash report from your CTR reporting software it can be helpful for reviewing cash transactions at an account level.

Don't know if this may help----I have our CTR parameters on cash ins and outs set at $3000 on trackable and non trackable transations. The parameters can be lower but tellers don't like it.

Well, we don't have any AML software, so we're limited in what we can do there.

Our cashed checks over $3K show on my large cash transaction report, I can pull an image to see the payee and manually compare to the report to see if that person shows up elsewhere. I guess my concern is what if someone cashes 6 $2K checks at different branches on a given day. I wouldn't see this due to being under $3K each.

Maybe very few of these instances would be identified even if we had a system in place. I just don't know what I'm missing.

Can you have your cashed check report pull all not on-us checks cashed? Also is you cashed transaction report pulling aggregate cahs deposits and withdrawals by account number?

That's what ours does. I also will go through the teller batched cashed checks and look for multiple checks to the same payee that fall under the threshhold and when aggregated exceed said threshhold.

My report does show non on-us checks cashed - if the amount of the check is >$3k. It will not show a bunch of checks <$3k cashed by one person.

Something else I don't like is that when someone cashes an on-us check (drawn on another customer of our bank), the cash out shows under the check writer's account. In this case, we're concerned with the check casher, who isn't identified for aggregation (other than by pulling a copy of the check and looking at the payee line).

I'll play Devil's Advocate (and take my lumps from the gurus) but, in the absence of automated software that can be 'tweaked' to relate certain parties, the manual steps being taken or suggested seem like a long way to go to give the bank knowledge of the situation. It seems 'hit and miss' enough that you're almost more likely to be criticized for what you missed than what you caught.

We don't have automated software either, and with six branches I'd be hard pressed to review teller batches at all, much less remember payees from one branch to the next.

I hear what you're saying dickr and agree to a point.

I guess my thoughts are that we can solve most of these issues by requiring our tellers to enter the TIN of the person who is cashing checks and making deposits into our online teller system. This will give us the information we're missing because now all of the cashed checks will be aggregated with any deposits/withdrawals. Management has already balked at this because it would slow down the tellers when the customers are in front of them. I thought this was becoming industry standard, but maybe I'm wrong.

Agreed. What it comes down to is whether of not a particular bank believes it's worth it. You have to believe that you might be missing something and that what you are missing might be important. Forget any idea that you will terminate the mechanism if you decide it's not cost effective. Examiners just don't comprehend that.

Auditor K, My understanding was that you did not have any automated capabilites. If you can do what you describe I suggest you do it.

We were requesting SSN/TIN information until we had quite a few angry customer that made us stop. (even though over 1/2 the time we had the information already) We don't have our automated system in place yet (very soon) but that should fix the problem.

We wouldn't have to ask the customer for this information - as long as the teller knows who's standing in front of her/him. We can do a look-up in our online teller system that will fill in the TIN field based on a name search. I agree that asking the customer for this information probably wouldn't be the best approach.

Auditor K, how big is your bank that allows your tellers to know the customer. If they do not, then you are back at square one at having to ask the customer for their TIN and create a profile to track them.

Curious, how many banks currently track these customers as suggested, or have you placed a dollar limit when it is required to gather the customer's information in order to proceed with the transaction.

Was doing some research on this topic, and was thinking about asking our tellers to start gathering id info on the conductors of cash transactions over $3k and entering it into a spreadsheet...is anyone else doing this, and what have the examiners said about it? Or, is it overkill? Thanks.

Oviedo Boy,

Out teller system requires that the teller enter id information for all cash deposits $3,000.00 and over

See what your core can do - if it can track by SSN, then this idea may work for you.

There was no way I was going to make my tellers get non-customer's SSNs, but we always get DL#.

Tellers are trained to enter a DL into where they would normally type the account number, omitting the letter that preceeds the numbers.

That way, each non-customer is given their own "account number" based on their DL#.


Works fabulously!

Good idea!

Before I had AML software, and before our teller system was upgraded we had difficulty identifying cash purchases of monetary instruments. We had the tellers put a $ symbol on one of the lines in the sales screen. When we got a transaction download we could easily tell which were cash purchases.

You have to get tricky sometimes.

I'm getting some push-back from the front line staff, since the previous BSA Officer did not require them to ask for ID on conductors of cash transactions by non-account owners. Is this type of monitoring mentioned in the BSA Exam manual, or anywhere I could refer back to for support?