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#2247892 - 01/20/21 07:42 PM Cash Transactions - Documentation of Reason
Carrie Offline
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Does anyone require their retail staff to document the reason for cash transactions over a certain dollar threshold? We are struggling because when cash transaction Alerts are generated in Verafin, the retail staff typically did not ask the purpose of the transaction(s) despite being trained to do so when a transaction appears to be out of the ordinary because they don't want to make the client uncomfortable or infringe upon their privacy. We thought that having them ask the reason for the cash transaction(s) for amounts above $3000 (or whatever the appropriate threshold may be) would help with this, but are getting strong pushback from the Retail Manager. Any input would be much appreciated!!! Thanks in advance.

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#2247894 - 01/20/21 07:50 PM Re: Cash Transactions - Documentation of Reason Carrie
ACBbank Offline
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I would opine that setting a $3,000 cash threshold across of all retail banking is going to lead to a lot of false positives. Certain businesses deal in cash and other don't. Further what's normal for Pizza Shop A may be abnormal for Pizza Shop B.

Do you have require clients to provide expected account activity during onboarding?
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#2247895 - 01/20/21 07:57 PM Re: Cash Transactions - Documentation of Reason Carrie
BrianC Offline
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#2247899 - 01/20/21 08:26 PM Re: Cash Transactions - Documentation of Reason Carrie
Carrie Offline
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Thanks for the responses! I should have clarified that we would require that the question be asked when there was no apparent business reason for the transaction and/or the transaction was out of the ordinary for the client. We're trying to reduce the number of SARs filed by asking retail staff to question the transactor(s) at the time of transaction. We thought that setting a threshold would result in a higher rate of compliance for asking the right questions if the reason wasn't apparent.

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#2247945 - 01/21/21 06:43 PM Re: Cash Transactions - Documentation of Reason Carrie
#Just Jay Offline
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Cheeseheadland
We too have set the threshold at 3k for cash in or out of consumer accounts, or for a business account that usually does not deal in cash, and as a result have improved the quality of our notes and results to alerts flagged in our AML software.

Granted, it does take a lot of time, training and practice to get staff comfortable with seeking the information, and even training customers to become forthright as well. And still, customers will decline to give answers, and that is fine and that is what is notated. We find more often than not, customers like to talk, so I feel we have a pretty high success rate at obtaining info from them.

Fortunately for me, our executive management team has always been supportive of our program so the message from the top has been incredibly helpful in making that successful.
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#2248005 - 01/22/21 03:17 PM Re: Cash Transactions - Documentation of Reason Carrie
edAudit Offline
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Fortunately for me, our executive management team has always been supportive of our program so the message from the top has been incredibly helpful in making that successful.

This is the key
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#2248525 - 02/02/21 01:54 PM Re: Cash Transactions - Documentation of Reason Carrie
New Manager Offline
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We require an email from the frontline for any cash transaction of $7,000 and above so we can use that when documenting alert and case notes. It's helped us to avoid some SAR filings since the explanation makes sense, and other times it lends more support to something we're not sure is suspicious, but turns out it is once we hear the explanation. We gear it towards consumers only since most of our businesses deal in cash and we know that.

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