If we only sale monetary instruments for cash between $3000 and 10,000 to customers is there any need to maintain a log of these sales? I know we are not required to maintain a log, but...I was just curious how many other banks did log such sales to customers and their reasoning behind it? (We currently log these transactions but are considering discontinuing it since all of the required information would be maintained elsewhere.)

I thought I might get some thoughts from BOLers before a final decision is made!! Thanks!!

The record of the sale of a monetary instrument should be maintained for all cash sales between $3000-$10,000 regardless of whether the sales are to customers. Guidance also indicates that we should maintain the record if we have the customer put the cash into an account and then subsequently debit the customer's account for the purchase.

Don't treat this as purely an academic process--these reports can be very valuable for identifying and researching suspicious activity. I recommend the records be aggregated and reviewed periodically to identify patterns that may have no apparent legitimacy.

As a follow-up to this issue, we always require customers to deposit cash to their account if they are purchasing a monetary instrument and then we debit the account for the MI. For this reason, we have not been completing the log, but now see the importance of doing so. However, if the cash deposit is for an amount different from the MI amount, higher or lower, how should the log be completed? For example, if the customer deposits $1,000 in cash and then purchases a $8,000 MI using the cash and the funds that were already in his account, how should we consider the transaction. If we enter on the log the $8,000 MI it may be inferred that the cash deposit was for this same amount, while it was only $1,000 in my example.

How do other banks specify this information?

Thanks.

You have to be able to identify those purchases that involve $3,000 or greater. Your example should not be captured. If you are unable to generate the the required data from, for example, your teller system, then manual logs are really required. Forcing the customer to run the cash through their deposit account sometimes defeats your ability to capture this information in an automated fashion.