We are looking to modify our cash transaction reporting. Basically, what minimum transaction value to use in our daily monitoring. I recognize factors such as risk profile should be considered. Within our AML policy we risk-rate ourselves as low. However, we currently have our reports set @ 1,000.

Just curious what other banks may use as thresholds or as factors in determining the thresholds.

Thanks!

You look at all cash transactions in excess of $1,000? That parameter seems really low. How this big is this report?

We use a couple of different types of cash reports to monitor for suspicious activity. A cash report by TIN, a structured transactions report and in/out report (Wire in, Cash out, etc.).

We have a cashed check report which can be 1-4 pages in length. Have a cash transaction report (sorted by TIN of who WROTE the check) this can be 3-8 pages. We have a pattern deposit report which shows activity for the last five business days - listed by TIN (use this to watch for any obvious structuring)....we also have a report that prints ALL cash-in or cash-out by TIN for that day of business. That can be upwards of 10+ pages. This classifies by non-reportable, merged, printed, or exempt.

I believe the bank historically has operated that as long as the report is getting printed, it is adding value to suspicious monitoring. Although, I don't even know how much review some of the reports are given.

Trying to get a handle on what is actually valuable and worth looking at.

Are all of these reports cut based on the threshold of $1,000?

If the cash transaction report is sorted by the TIN of who wrote the check, and another report that prints ALL cash-in or cash-out by TIN for that day of business, aren't you duplicating efforts? I may have misinterpreted the information, but that's certainly what it sounds like to me.

There's no value in generating massive reports that someone does nothing more than glances at, especially if you're printing these out. From my experience, the more I've delved into reports that I didn't understand/saw no value in, there truly was no value, and "it's what we've always done" was the mentality. If the report is viewed for a specific and proven reason, keep it. If the report is generated just to boost the number of reports that the department creates, eliminate it.

Another area you may want to consider is non-customer check cashing. I recently created a report to monitor the check cashing of non-customers, as there's a slight loophole in our system where they can potentially exceed 10k, as we have a 5k per item threshold for non-customers, but with the use of multiple locations, can be exploited. By generating a report of all non-customer check cashing activity, and sorting by the Payee, we are able to monitor this, and also account for the clerical errors of the tellers that type in the non-customer names in the Payee field.

I would like to re-open this topic, if I may. Our teller system currently is set to prompt the teller to enter the conductors SSN name and ID information, if not previously provided, for cash out transactions of $3,000 or greater and for cash in transactions greater than $10,000. For consistency and broader aggregation, we are considering lowering the cash in threshold amount to $3,000 also. We are a $5 Billion bank.

I am interested in hearing what other banks have set their thresholds to. If you have changed your thresholds and how this was received. And, if you believe this to be a good or bad idea and why.

here are my questions:

why?
what are you thinking this will provide to your bank?
have you looked at how much additional information this may provide?
what will you do with this additional information?
are you staffed to take on this additional process?
are you prepared to address with commercial clients that have employees performing deposits and the blowback this may generate?

ours are set at regulatory limits and can't imagine why we would want to change it. we have an intuitive BSA system that alerts us to potential patterns that fall within regulatory limits (such as structuring) that we can then monitor as needed. But to just add additional work? not sure i see a reason why (although someone on BOL may offer reasons i'm not currently thinking of, they are great with that).