Wednesday, July 11, 2018
(the ATM Industry Association) today announced its support for . The Counter Terrorism and Illicit Finance Act includes language that would increase the current threshold for requiring completion of a Currency Transaction Report (CTR) from $10,000 to $30,000. Banks must complete CTRs when they facilitate cash transactions greater than the threshold, which creates additional burden and expense for legitimate transactions between legitimate businesses.
The $10,000 threshold established when CTRs were first implemented by the Bank Secrecy Act (BSA) has not changed in nearly 50 years. During that same period, inflation has increased the value of $10,000 to about $65,000 today. Or looking at the reverse situation, it would be the same as the regulators in 1970 establishing a threshold of merely $1,500 for cash transaction reporting.
As time has passed, banks have been forced to complete more and more CTRs – making it more and more costly for them to service independent ATM operators. It is clearly time to adjust the CTR threshold to a more realistic level, better aligned with the true value of today’s transactions.
“It is simply a myth that ATMs serve as an efficient vehicle for laundering cash,” says ATMIA U.S Executive Director, . “The ATM cash cycle is very transparent and constantly monitored by the ATM networks and payment processors. An increase in CTR threshold will benefit many small businesses, without any negative impact on AML controls.”
ATMIA has also just released an infographic called . It illustrates and describes how cash moves through the cycle of ATM cash loading and customer withdrawals, and maps out the numerous checks and balances. Information is also provided on the strict vetting that ATM operators are subject to – including regular OFAC (Office of Foreign Assets Control) checks.