Cash Reporting Requirements for Banks

December 4, 2020

In many jurisdictions, federal law requires a person or business to report cash transactions above a certain threshold in order to help prevent instances of money laundering. Here is a sample of some of the cash reporting requirements in different regions.

 

FinCEN – U.S.

According to FinCEN, U.S. federal law requires financial institutions to report currency (cash or coin) transactions over $10,000 conducted by, or on behalf of, one person, as well as multiple currency transactions that aggregate to be over $10,000 in a single day. Transactions are reported on Currency Transaction Reports (CTRs).

 

IRS – U.S.

The Internal Revenue Service in the United States requires trades and businesses to report cash payments received if all of the following criteria are met:

  1. The amount of cash is more than $10,000
  2. The business receives the cash as:
  • One lump sum of more than $10,000, or
  • Installment payments that cause the total cash received within one year of the initial payment to total more than $10,000, or
  • Previously unreported payments that cause the total cash received within a 12-month period to total more than $10,000
  1. The establishment receives the cash in the ordinary course of a trade or business
  2. The same agent or buyer provides the cash
  3. The business receives the cash in a single transaction or in related transactions

 

FINTRAC – Canada

If you are a reporting entity in Canada, you have to send a large cash transaction report (LCTR) to the country’s financial intelligence unit  in the following situations:

  • You receive an amount of $10,000 or more in cash in the course of a single transaction; or
  • You receive two or more cash amounts of less than $10,000 that total $10,000 or more (24-hour rule). In this case, if you are an individual, you have to make a large cash transaction report if you know the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity. If you are an entity, you have to make a large cash transaction report if your employee or senior officer knows the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity.

LCTRs must be sent to FINTRAC within 15 calendar days after the transaction.

 

AUSTRAC – Australia

As a reporting entity in Australia, you must report transfer of physical currency of A$10,000 or more (or the foreign currency equivalent) to AUSTRAC in a threshold transaction report (TTR) within 10 business days.

 

EU

According to the European Union, whether acting as a business owner or as an individual, you should apply certain measures when you are entering into a business relationship or carrying out occasional transactions with customers to prevent money laundering and terrorist financing.

These measures apply for a single operation or in several operations that appear to be linked if you are:

  • trading in goods, and payments are made or received in cash for €10 000 or more
  • carrying out an occasional transaction that amounts to €15 000 or more
  • a provider of gambling services involved in the collection of winnings or the wagering of a stake, when carrying out transactions amounting to €2000 or more

The organization also states that in these situations you have to apply customer due diligence, including identifying and verifying the identity of the customer as well as the beneficial owner. If you suspect any suspicious activity you should report it to the financial intelligence unit (FIU) in your EU country.

 

FIC – South Africa

According to the Financial Intelligence Centre (FIC), accountable and reporting institutions must report single cash transaction to the value of R25 000 or more, or an aggregation of smaller amounts with a combined value of R25,000 or more. While the aggregation period is not specified, the Centre requests that a period of at least 24 hours be applied when considering aggregation.

 

Bank Negara Malaysia – Malaysia

In Malaysia, currency transaction reports must be reported for cash transactions exceeding RM25,000 (single or multiple cash transactions within the same amount specified in a day) involving physical currencies (domestic or foreign currency) and bearer negotiable instruments such as travellers’ cheques but excludes bank drafts, cheques, electronic transfers or fixed deposit rollovers or renewals.

These include transactions involving withdrawal of cash from accounts or exchange of bearer negotiable instruments for cash.

 

STRO – Singapore

Singapore’s Financial Intelligence Unit is the Suspicious Transaction Reporting Office (STRO) and it says that if you are a regulated dealer under the PSPM (Prevention of Money Laundering and Terrorism Financing) Act, you are required to submit a CTR to the STRO and a copy separately to the Anti-Money Laundering/ Countering the Financing of Terrorism Division (ACD) when:

  1. You sell any precious stone(s), precious metal(s), precious product(s) (“PSPM”) or asset-backed token(s) to a customer and receive cash or cash equivalent exceeding SGD 20,000 as payment;
  2. You conduct two or more sales of any PSPM or asset-backed token(s) in a single day to the same customer, or to customers whom you know act on behalf of the same person and receive cash or cash equivalent in total exceeding SGD 20,000 as payment;
  3. You (as a secondhand goods dealer) purchase any PSPM from a customer (who is not a regulated dealer) and pay cash or cash equivalent exceeding SGD 20,000;
  4. You (as a secondhand goods dealer) make two or more purchases of any PSPM in a single day, from the same customer, or customers whom you know are acting on behalf of the same person (none of whom are regulated dealers) and pay cash or cash equivalent exceeding SGD 20,000;
  5. You redeem an asset-backed token(s) from a customer (who is not a regulated dealer) for cash or cash equivalent in total exceeding SGD 20,000; or
  6. You conduct two or more redemptions of any asset-backed token(s) in a single day from the same customer, or customers whom you know act on behalf of the same person (none of whom are regulated dealers), for cash or cash equivalent exceeding SGD 20,000.

Pawnbrokers must submit a CTR and a copy separately to the Registry of Pawnbrokers (ROP) when:

  1. They sell any PSPM to a customer and receive cash or cash equivalent exceeding SGD 20,000 as payment; or
  2. They conduct two or more sales of any PSPM in a single day to the same customer, or to customers whom you know act on behalf of the same person and receive cash or cash equivalent in total exceeding SGD 20,000 as payment.

Casinos are required to submit a CTR to the STRO, before the end of the applicable reporting period, for:

  1. Every cash transaction with a patron involving either cash in or cash out of SGD 10,000 or more in a single transaction; or
  2. Multiple cash transactions which the casino operator knows are entered into by or on behalf of a patron, the aggregate of which is either cash in or cash out of SGD 10,000 or more in any gaming day.

 

CAMLMAC – China

According to KPMG, financial institutions shall report large-value and suspicious transactions to the China Anti-Money Laundering Monitoring and Analysis Centre (CAMLMAC) which meet the following criteria:

  • Any single cash transaction with a value over RMB50,000, or any series of cash transactions with an accumulated value exceeding RMB50,000 in a single day.  The threshold for foreign currency transaction is US$10,000 (or equivalent in other foreign currencies) with transactions in scope including cash deposit, cash withdrawal, sale and purchase of foreign exchange with cash, cash exchange, cash remittance, cashier’s check payment and other cash transactions.
  • Any fund transfer above RMB 2,000,000 (or, for foreign currency transfers, US$200,000 or equivalent) between bank accounts of legal persons and 3rd party bank accounts. This is whether the transfer is a single lump sum or the accumulative total transferred on a single day.
  • Any fund transfer above RMB500,000 (or, for foreign currency transfers, US$100,000 or equivalent) between bank accounts of natural persons and 3rd party bank accounts. This is whether the transfer is a single lump sum or the accumulative total transferred on a single day.
  • Any cross-border transaction above RMB200,000 (or, for foreign currency transfers, US$10,000 or equivalent) where one party involved in the transaction is a natural person. This is whether the transfer is a single lump sum or the accumulative total transferred on a single day.

The following article is intended as a guide. To obtain current reporting requirements, please contact the financial intelligence unit for that jurisdiction.

To learn about how Alessa can assist with monitoring transactions that need to be filed to your financial intelligence unit, contact us.

 

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