Regulatory Alerts2002-11-26
Added
Guidance on Interpreting Financial Institution Policies in Relation to Recordkeeping Requirements Under 31 C.F.R. §103.29
FinCEN clarifies that financial institutions must comply with the recordkeeping requirements of 31 C.F.R. §103.29 when customers purchase monetary instruments between $3,000 and $10,000 using currency, even if the currency is first deposited into the customer's account. Institutions are required to retain these records for five years and make them available upon request to FinCEN or agencies with delegated authority. Additionally, multiple purchases of monetary instruments on the same business day totaling between $3,000 and $10,000 must be treated as a single purchase if the institution has knowledge of the transactions, requiring appropriate procedures to control money laundering risks and determine if a suspicious activity report is warranted.