Currency Transactions Reports (CTR)
What is the purpose of filing a CTR?
Currency transaction reports are used to assist financial institutions with identifying money laundering or other illegal activities.
How long does NPFCU have to file a SAR?
30 calendar days after the initial date of detection.
What does FinCen do?
FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security.
The board must approve one of these each year.
What is a BSA policy?
A member brought in $4,500 in cash at 9:30 am to be wired to an account in Idaho. They returned at 11:00 am with another $4,500 in cash to be wired to an account in Florida. The member again came in at 3:00 pm with $1,100 cash to be wired to an account in Wichita. This is required of the credit union to submit.
What is CTR and SAR?
How many days does NPFCU have to properly file a CTR?
15 days
When is the credit union required to file a SAR?
When it detects a known or suspected criminal violation of federal law, a suspicious transaction related to potential money laundering, or a violation of the Bank Secrecy Act (BSA).
In order to comply with OFAC policy when is the Credit Union required to run members through OFAC?
Each transaction is subject to being checked against OFAC to ensure it is not a prohibited transaction and each new account is checked prior to doing business with the member.
This term is abbreviated AML.
What is anti money laundering?
This person or group is ultimately responsible for the BSA compliance.
Who are the board members?
The BOD is ultimately responsible. The BSA Officer is responsible for monitoring day to day BSA/AML compliance and managing all aspects of the BSA compliance program.
When is NPFCU required to file a CTR?
When a deposit, withdrawal, exchange of currency, involves more than $10,000 in currency.
Can we disclose to a member that we are filing a SAR?
No, never!
What does OFAC stand for?
Office of Foreign Assets Control
True or false, it's not necessary for the CU to report to the board when a CTR or SAR is filed?
False
How often are we required to have an external auditor review our CU for BSA/AML compliance?
This audit is an annual requirement.
Name at least five pieces of information required to fill out a CTR?
Name of individual conducting transaction(not account owner)
Address
Identification (ex. driver licenses)
Social Security Number
Amount of transaction
Is the board notified of a SAR filing?
Yes, but notification only. No details.
This office publishes lists of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific.
What is OFAC?
The name of our BSA compliance officer
What is....me!
This is the term for actions taken by a member to be sure that their deposits are under the reportable amount, even if it means they have to come in several days in a row.
What is structuring?
Member makes a deposit a $7,000 cash deposit on Monday at 9 am. The member leaves and comes back at 4:30pm on the same day, and deposits $4,000 in cash. Does this situation warrant a CTR?
Yes, both transactions occurred on the same business day and total more than $10,000 in cash.
Member comes into the branch once a week with $5,000 in hundred dollar bills. The member deposits $2,500 into checking account then asks for smaller bills with the other half. When teller asks where funds are coming from, member would not say. Would you or would you not file a SAR?
Since this a occurring weekly, a SAR should be filed.
How often do we check our membership listing against the FinCen list of folks we cannot do business with?
Every two weeks a new list is generated and checked against the membership.
This can happen to the credit union if we intentionally disregard the BSA/AML requirements.
What is being assessed significant fines and penalties.
True or false, we should never talk to members about CTR and the thresholds that trigger a report.
False. In fact, the government publishes informational pamphlets describing the process and when a report is necessary. This one is not confidential.