I would like to know how everyone checks the cash transactions from $3,000-$10,000 to ensure that they have been logged properly. I just completed my review and found several transactions that were missing. It was VERY tedious and if anybody has any short cuts or ideas it would be greatly appreciated.

Right now, I create a report to draw data from each clearing account and then I have to find out if the offsetting entry is cash.

We've set the threshold of our large cash report to catch these. If it's a cash in to the cashier's check account, it should be logged!

We select a sample of days in the audit period and look up cash-in entries $3,000 to $10,000. (electronically) Tellers use the Barclay On-Line system to enter a short description on all cash tickets. When performing item research, we look for the "misc OC sale" description on the ticket and electronically research the transaction. We also research electronically the g/l account "fee income for official check sales" as a cross check. Same for transactions over $10,000 with a cross check using a report which lists and aggregates all cash transactions over $10,000.

We are not as lucky as the last poster. Our system does not distinguish between a true "cash" transaction and any other transaction. I am currently performing our BSA audit, and ours is also very tedious. There are two ways that I use to verify compliance. First is (keep in mind we only have 3 branches) to pull the tellers blotters for any given day within the testing period and manually select cash transactions and then trace them through the entire reporting process. Secondly, you can select transactions from the monetary instrument logs and then verify that the CRT was properly filed and that the transaction was actually a "cash" transaction. Also, we have other internal reports that these transactions are logged onto, so I check those as well. For example, since our system does not automatically recognize cash transactions, our teller supervisor has created an AML Cash Transaction report. This report is an aggregate report of all cash transactions in excess of three thousand dollars and is compiled monthly. So I check to make sure that the selected transaction has ended up on this report. So I am in your boat that it is a tedious process, but a necessary evil I'm afraid. Good luck.

My opinions do not necessarily reflect those of my employer.

I am a registered user - posting anonymously for obvious reasons. I recently performed a BSA audit and found serious problems in our recording of MI purchases of $3,000 - $10,000 in cash. According to my 1 month audit we only have 22% of reportable transactions actually listed on our log! We have addressed the issue and found a control to help insure that all transactions are reported in the future. My problem is what do I do about the past? I have one months worth of transactions that I know, should they be added? what about the other months? how far back should I go?

Same Anon as above....what are the specific penalties for section 103.29 which requires that we maintain these records. I am working on a memo to staff about the importance of this provision and what to use the penalties to show them the severity of this issue.

Bank Secrecy Regulation

Sec. 103.57 Civil penalty.

(c) For any willful violation of any recordkeeping requirement for financial institutions, except violations of Sec. 103.32, under this part, the Secretary may assess upon any domestic financial institution, and upon any partner, director, officer, or employee thereof who willfully participates in the violation, a civil penalty not to exceed $1,000.

Sec. 103.59 Criminal penalty.

(a) Any person who willfully violates any provision of Title I of Pub. L. 91-508, or of this part authorized thereby may, upon conviction thereof, be fined not more than $1,000 or be imprisoned not more than 1 year, or both. Such person may in addition, if the violation is of any provision authorized by Title I of Pub. L. 91-508 and if the violation is committed in furtherance of the commission of any violation of Federal law punishable by imprisonment for more than 1 year, be fined not more than $10,000 or be imprisoned not more than 5 years, or both.

(b) Any person who willfully violates any provision of Title II of Pub. L. 91-508, or of this part authorized thereby, may, upon conviction thereof, be fined not more than $250,000 or be imprisoned not more than 5 years, or both.

(c) Any person who willfully violates any provision of Title II of Pub. L. 91-508, or of this part authorized thereby, where the violation is either
(1) Committed while violating another law of the United States, or
(2) Committed as part of a pattern of any illegal activity involving more than $100,000 in any 12-month period, may, upon conviction thereof, be fined not more than $500,000 or be imprisoned not more than 10 years, or both.

(d) Any person who knowingly makes any false, fictitious or fraudulent statement or representation in any report required by this part may, upon conviction thereof, be fined not more than $10,000 or be imprisoned not more than 5 years, or both.

I guess were pretty lucky because our managers print out a report that lists all CC, Money Orders, and Travelers cheques that were purchased for that day. It lists what was used to purchase...If there's a cash in on the report for more than $3000...then the manager knows that a report should have been files....

This is why some banks will not sell cashier's checks for cash anymore. Consider adopting a policy that requires customer's to first deposit cash into their deposit account. This means you can't sell monetary instruments to non-customers. (Who would want to do this in this environment anyway?) There are other threads regarding this.

Keeping manual logs is a recipe for disaster in my opinion. Too much room for human oversight. See if your teller system has the ability to create a log if you really feel that you want to continue selling monetary instruments for cash.

Our AML system now has an On-Line Monetary Instrument log that requires the teller (or other issuer) to enter the information for ANY Monetary Instrument whether purchased by check or by cash, customer, or non-customer. The customer is easier because the fields will fill in with customer information after their account number is entered.

It makes the 314(a) searches easy, and it gives us a complete log of everything - including the ability to spot structured purchases below $3,000.

Our teller system logs this for us, all purchases, whether cash, check or debit to account. It exports to a file that can be sorted to search for multiple transactions by same person, etc.

Dolly,

We were told that requiring customers to deposit before purchasing monetary instruments did not relieve us of the record keeping requirements - in short, the customer's intent was to purchase with cash, so we had to include those transactions. Have you come across examiners with a different opinion?

The requirement is that you must be able to provide the information, whether it is in a manual log or retrievable from your system. Many banks require the deposit of the cash because that then allows them to capture the transaction for this purpose and others such as cash aggregation for CTRs. Requiring a deposit of the cash does not eliminate the need to have the information available - it is still a cash purchase of monetary instruments.

See Kaybee's response. It also makes it easier to monitor for suspicous activity as all cash goes through the customer's account(s).