Strengthening an Anti-Money Laundering Program: Best Practices for Cash Transactions

Strengthening an Anti-Money Laundering Program: Best Practices for Cash Transactions

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Question

Which of the following is MOST effective in strengthening an anti-money laundering program involving cash transactions?

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A. B. C. D.

D

All the options mentioned in the question can be effective in strengthening an anti-money laundering program involving cash transactions. However, option B, completing CTR worksheets on all cash transactions of $5,000 or more, is generally considered the most effective approach.

A Currency Transaction Report (CTR) is a form that must be filed with the Financial Crimes Enforcement Network (FinCEN) by financial institutions for any cash transaction over $10,000 in a single business day. However, some institutions may choose to complete CTR worksheets on all cash transactions of $5,000 or more as a precautionary measure. Completing CTR worksheets allows financial institutions to document the transaction information and verify the customer's identity, which can help identify suspicious or fraudulent activity.

Option A, reviewing all deposits of $25,000 or more, can also be effective in identifying suspicious activity. However, it may not capture suspicious activity in smaller transactions.

Option C, completing Suspicious Activity Report (SAR) worksheets on all cash transactions of $5,000 or more, can also be effective in identifying suspicious activity. SARs are used to report suspicious transactions to FinCEN, and financial institutions are required to file SARs for certain types of suspicious activity. However, completing SAR worksheets on all cash transactions of $5,000 or more may not be necessary if the transactions do not meet the criteria for suspicious activity.

Option D, monitoring cash transactions of less than $10,000 for suspicious patterns, can also be effective in identifying suspicious activity. However, it may not capture suspicious activity in larger transactions, and it may not be as efficient as completing CTR worksheets on all cash transactions of $5,000 or more.

In summary, completing CTR worksheets on all cash transactions of $5,000 or more is generally considered the most effective approach in strengthening an anti-money laundering program involving cash transactions. However, financial institutions may choose to use a combination of approaches to ensure that they are effectively identifying and reporting suspicious activity.