Currency Transactions Reports (CTR)
Currency transaction reports are used to assist financial institutions with identifying money laundering or other illegal activities.
What is the purpose of filing a CTR?
Detects a known or suspected criminal violation of federal law, suspicious transaction related to potential money laundering, or violation of the Bank Secrecy Act (BSA)
When a SAR is required?
Provides a unique service to law enforcement to help locate financial assets and recent transactions done by subjects of criminal investigations
What is Financial Crimes Enforcement Network (FinCEN)?
Section 326 of the USA Patriot Act requires a CU to implement a written program
What is a Customer Identification Program (CIP)?
A mechanism for the credit union to adhere to safe and sound banking practices.
What is CDD (Customer Due Diligence)?
10 calendar days/15 calendar days
How many days a FI have to properly file a CTR?
Our deadline / filing deadline
30 calendar days after the initial date of detection
When a SAR needs to be filed with a known suspect?
Laws and regulations that promote national and international security by requiring asset freezing
What is Office of Foreign Assets Control (OFAC)?
Name, date of birth, residential or business street address, and identification number
What are the required information needed from member to complete the CIP form?
Required information a financial institution needs to obtain, verify and record on owners and legal entity
What is a Beneficial Ownership information?
Deposits, withdrawals, exchange of currency, or other payments or transfers exceeding $10,000 in currency
When is it required to fill out a CTR?
Disclosing to a member that we are filing a SAR
What should we never do?
List of individuals and groups that OFAC provides
What is the Specially Designated Nationals (SDN) or Specially Designated Global Terrorists (SDGT) list?
Driver's license, Passport, Federal/State ID, Military ID
What are some Primary Documents used for member's verification?
Used to complete a Customer Due Diligence form
What is VeraFin?
Name of Conductor, address, identification, SSN, and amount of transaction
What are the information required to fill out a CTR?
Who's involved, what happened, when and where if happened, and why
What type of information should be gathered if a SAR is warranted?
within 10 business days
When does a financial institution needs to report an OFAC match?
A special rule of using a Secondary or Other Documents for verification.
What is the Special rule for Minors?
Questions are based on the type of accounts to help identify these types of members
What are High-Risk members?
5 years
What is the retention period for CTRs?
Written investigative demands to obtain financial records from financial institutions
What is a National Security Letter?
Requirement to search financial records to identify any data match to a particular investigative subject
What is 314a program?
Notice in clear view, and/or provided to members before opening an account
What is the USA Patriot Act notice?
CDD questionnaires for all new accounts on Verafin will score their answers in four categories
What is entity risk, product risk, geographic risk, and SAR volume?