Tracking of Currency Exchanges - CTR Filing

In attempting to create efficiencies and eliminate a paper currency exchange log, I have requested the Branches to use the core system to track the exchanges (entered through a business task). We now have the capability to upload that information into our AML software to use for required filing purposes (CTR & SAR). Currently a very manual process.

I'm getting pushback from the branches about having to use the core system task (which has been tested and only takes seconds to process). I am baffled since I would think the paper logging process is more time-consuming.

How are currency exchanges handled in your bank? Do you set a minimum dollar limit that exchanges are required to be recorded? All are currency exchanges, no matter the amount, or whether personal or business, required to be recorded?

What is your Risk tolerance for currency exchanges?

I currently require ALL currency exchanges to be recorded using the core system task so that they will then be imported into our BSA software. I had considered setting a minimum dollar limit, but decided against it since our branch/teller staff responds more favorably to an 'all in' approach.

In our bank, any currency exchange over $1,000.00 is required to be run through a dedicated GL. BSA monitors the GL's that accept cash daily, so we would know to expect a CTR or a MIL entry.

Doug,

That's exactly what I tried, the "all-in approach" and that is where I am getting the pushback.

Thanks for the input.

This was one more thing I didn't want a teller to have to think about (gee, was the limit $100 or $1,000). If they do them all it helps to speed up the process.

I did $1,000.00 because prior to that the whole thing was happening 'off-book' in the teller window and I was relying on a MIL entry or CTR to be done. For our size bank the threshold did not worry me and 'the good is not the enemy of the perfect' at the end of the day.

Madawaska --

I don't think the tellers' gripe is about the task, although they may think it is. What has upset them, I'll bet, is the CHANGE in procedure. Once they have the new procedure down as routine, they'll wonder what all the fuss was about, I can almost guarantee.

Agreed. I often found it necessary to remind a few of them that whatever the "extra" work was, they were getting paid for every minute of their time.