For a brochure providing BSA/AML information to customers, you may want to use FinCEN’s CTR Reference Guide, which explains the currency transaction reporting (CTR) requirements. A FinCEN notice suggests distributing this pamphlet to customers, “such as when a customer opens an account and expects to handle large amounts of currency or when a customer has questions about particular currency transactions.” Of course, your tellers and staff should be trained on the CTR structuring rules, which prohibit any person from structuring, or assisting someone to structure, currency transactions for the purpose of evading the CTR reporting requirements. 31 CFR 1010.314(c)31 CFR 1010.100(xx) (definition of “structuring”).
Our Board asked us to put some sort of brochure or one page document together on BSA and Compliance related matters for the customer to pick up while at the branch. Is this permissible?
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