Skip to content
BOL Conferences
Thread Options
#1473827 - 11/30/10 06:19 PM Cash Exchanges
KDF Offline
Member
KDF
Joined: Jul 2009
Posts: 79
Minnesota
I'm wondering what, if any, procedures other banks have in place for monitoring cash exchanges for money laundering, i.e. a customer comes in with $5,000.00 in twenties and asks for hundreds. Are you writing tickets? Keeping some kind of log? Do you ask the person requesting the cash exchange their name? If the exchange is greater than $10,000.00 are you completing a CTR?
_________________________
"Sometimes that light at the end of the tunnel is a train."
Charles Barkley

Return to Top
BSA/AML/CIP/OFAC Forum
#1473834 - 11/30/10 06:25 PM Re: Cash Exchanges KDF
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I'll take this one:

Quote:
If the exchange is greater than $10,000.00 are you completing a CTR?


Yes, they definitely are. The regulation requires the reporting of currency exchanges. That's true even if the customer is recognized as a Phase II exempt person.

Currency exchanges by a customer recognized as a Phase I exempt person are not reportable.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1473836 - 11/30/10 06:28 PM Re: Cash Exchanges KDF
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
We treat it as a cash in and cash out on the system. No tickets will get produced, but the transaction will hit our $3,000 - $10,000 or CTR report as approriate. We do get the customer's information.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

Return to Top
#1473882 - 11/30/10 07:40 PM Re: Cash Exchanges Doug Hendrickson
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
All currency exchanges get processed through teller and are aggregated with other currency transactions. If the other currency transactions and the exchange meet the $10,000.01 threshold, a CTR is filed.

A CTR would be filed if it were just an exchange as well over $10,000.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1474710 - 12/01/10 08:58 PM Re: Cash Exchanges J2C
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
During our last exam (OCC) we were questioned on our procedures for currency/cash exchanges and we really had not addressed it.

We now do cash in and out tickets for all transactions between 3,000 - 10,000, have a currency exchange ticket completed which lists the incoming denominations and outgoing denominations and have the customer sign it. This is sent along with the CTRs to BSA for monitoring.

Cash is aggregated along with deposits and withdrawals and if it meets filing criteria, CTR will be completed.

Hopefully it will satisfy examiners during the next exam.

Return to Top
#1623760 - 11/02/11 09:05 PM Re: Cash Exchanges NewTooBSA
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 335
Kansas
What about if a customer comes in to purchase a cashiers check for $5000 and the bank has them deposit the cash into their account and then debit their account for the purchase. Wouldn't this be circumventing the law?

Return to Top
#1623773 - 11/02/11 09:19 PM Re: Cash Exchanges Patricia
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Some institutions do this because that is the only way their AML tracking software can attach the cash to the customer. It does not circumvent the law because FinCen has issued guidance that requires these institutions to still record the Cashier's Check sale on their Monetary Instrument Log.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#1623774 - 11/02/11 09:19 PM Re: Cash Exchanges Patricia
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
No. It's referred to as an "indirect purchase" and is blessed in the Handbook on page 107. The practice does not eliminate the record retention requirement.

Although the practice has an official blessing and it makes a lot more sense than keeping a log, it really confuses some auditors and examiners.

Brian was just kidding about that log thing, you're not required to have one. wink
Last edited by Ken_Pegasus; 11/02/11 09:21 PM. Reason: Add comment about log
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z