Currency threshold transactions have long been a cornerstone of anti-money laundering (AML) regulations worldwide. The requirement for financial institutions to report large cash transactions above a specified threshold aims to detect illicit financial activity and promote transparency. However, in an increasingly digital economy, where electronic payments dominate, the effectiveness and necessity of such reporting mechanisms are being questioned.

In this episode of AML Connections we consider the global standards for currency transaction reporting (CTR) under the Financial Action Task Force (FATF) framework, compares jurisdictions with and without currency reporting thresholds, and examines recent regulatory shifts, such as the Financial Crimes Enforcement Network’s (FinCEN) move to lower record-keeping thresholds along certain U.S. geographic corridors. Additionally, this paper evaluates the argument for increasing the CTR threshold in the U.S. and critically assesses whether threshold-based reporting remains an effective tool for detecting suspicious activity in an economy where cash usage is diminishing. Finally, we explore recommendations on adapting AML strategies to align with evolving financial realities.

CTRs, Yae or Nae?

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