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#79140 - 05/09/03 02:44 PM Monetary Instruments Log
Anonymous
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How does everyone monitor the sale of monetary instruments to determine if multiple sales to or for same person were made in a single day when the purchaes were for amounts less than $3,000 each time but totaled $3,000 - $10,000 for the same business day??? Part II, do you obtain all information required to complete the form on ALL non-customer purchases of any instrument sold ? I hope there's a better way. HELP!

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Audit
#79141 - 05/09/03 03:06 PM Re: Monetary Instruments Log
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Unless you already have some type of automated system to track your sales, I wouldn't do it. The regulatory requirement is to report if you have knowledge. There is no requirement to go to extrordinary steps to obtain the knowledge.
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#79142 - 05/09/03 03:24 PM Re: Monetary Instruments Log
Anonymous
Unregistered

That's what we wanted to hear. Even though there's not requirement for a centralized log, do you recommend that
someone review those logs to determine if a CTR is required due to multiple sales on the same day by same purchaser exceeding $10,000? Again, we don't want to do anything that's not required.

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#79143 - 05/09/03 03:40 PM Re: Monetary Instruments Log
KYAuditor Offline
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KYAuditor
Joined: Jan 2003
Posts: 138
Kentucky
Our BSA Officer reviews the logs from all branches to determine if any reportable transactions have occurred.
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Just my 2 cents worth--for what its worth!!

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