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Aggregating multiple branch cash activity

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If a Private Banking institution with multiple branches has a client withdraw or deposit cash funds that aggregate to over $10,000 in one day among the branches, what is the bank's responsibility with regards to CTR filing? Are they expected to monitor client activity from one branch to another?

Although there is no official regulation requiring aggregation of cash activity across branches, if a bank does not have the capability of doing so, we must face practical realities: I just don't think this argument will fly any longer.

Bank systems have evolved so that cash transaction aggregation by account should be the norm, rather than the exception. Regulators are increasingly citing banks and exacting penalties for failure to have in place adequate controls to detect and report money laundering.

Private banking is one of the "red flag" areas that interests examiners when doing AML examinations. I believe that any private banking operation that hasn't gotten this message by now is betting heavily on very poor odds.

First published on 11/29/04

First published on 11/29/2004

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