UPDATE-And Clarification

We are now advised that the new Task Force is reviewing not only the Criminal Referral Form (CRF), but also the Currency Transaction Report (CTR) with an eye towards revision-target date unknown. We'll keep asking!

In the meantime, FinCEN came out with the following:

"When a pattern of suspicious behavior by an identifiable individual is detected, the rules require a financial institution to file a report no later than 30 calendar days after the aggregate amount of associated transactions exceeds $1,000. The $1,000 reporting threshold aids law enforcement in detecting patterns of offenses involving small losses. Some criminal activity could be missed if not combined and examined in the aggregate, particularly money laundering and check fraud cases. Illegal transactions that warrant a CRF include:
Bank Secrecy act violations, including structuring
Money Laundering
Embezzlement
Check Kiting
Credit Card Fraud
Bank Fraud
Misuse of position or self-dealing
False statements
Bribery
Mysterious disappearance of funds

Copyright © 1994 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 4, No. 8, 2/94