The $3,000 Log Is Gone Forever...BUT

Some information still required on Non-Depositors
The need to maintain the $3,000 log for the sale of monetary instruments between $3,000 and $10,000 in cash is no longer in effect. It disappeared with the application of pen to paper on Friday, October 14-and it was effective as of the signing on that date.

The major changes are that you no longer need ask if the purchaser is acting "on behalf of" someone else; and you do not have to put any of the information on a separate record (such as the log); nor do you have to forward the information to a central location. As long as you can retrieve the information from "somewhere" for the next five years, you are in compliance.

BUT...Non-Depositor Information Still Required
Customers are still expected to deposit cash into their accounts and use withdrawals or checks to purchase monetary instruments. And if you don't sell monetary instruments to non-depositors, you're home free.

But if you do sell to non-depositors, the information that you have to record and keep is the name, address, social security number or alien ID number, the date of birth, the date of the purchase, the type of instrument (money order, travelers check, etc.), the serial number, the amount in U.S. dollars, and the method of identification used. You may put this information on the tissue of the money order, or on your travelers check records, or on the branch copy of the cashier's check, or in some similar fashion. All Treasury want to know is that you can find this information somewhere.

You can get more information on the change of the $3,000 Rule by using your PC to call the Bank Secrecy Act Bulletin Board (BSABB) at (313) 961-4704. It has been updated to include all the information just released.

Copyright © 1994 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 5, No. 3, 11/94