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Reporting Obligation

In terms of the Rules notified under Prevention of Money Laundering Act, 2002 (PMLA) certain obligations were cast on banking companies with regard to reporting of certain transactions. Accordingly, Banks are required to make the following reports to the FIU- IND.

  • Cash Transaction Reporting (CTR)
  • Counterfeit Currency Reporting (CCR)
  • Suspicious Transaction Reporting (STR)

Cash Transaction Reporting (CTR)

As per the PMLA rules, Bank is required to submit the details of,

  • All cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency.
  • All series of cash transactions integrally connected to each other, which have been valued below rupees ten lakh or its equivalent in foreign currency, where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh.
  • The format for reporting of the above-mentioned cash transactions, known as Cash Transaction Report (CTR) has been provided by the RBI through its Circular.
  • RBI vide circular dated May 22, 2008 has clarified that Cash transaction reporting by branches to their controlling offices should be submitted on monthly basis.
  • While the circular provides both manual as well as electronic formats for submission of CTR, banks have been advised to initiate urgent steps to ensure electronic filing of CTR.
  • In case of Banks who have implemented software solutions for AML, CTR generation module forms part of the standard suite of the software.
  • Some Banks who have not availed of AML software may require their technology departments to institute suitable procedures for extraction of data and arranging the same in form of text files in specified format every month.
  • The FIU-IND has provided an Excel based utility at its website www.fiuindia.gov.in for generation of CTR in electronic form. This could be used by banks that do not have a core banking system. After following steps instructed by FIU-IND therein, the said utility automatically generates a set of 6 files for onward reporting to FIU-IND.
  • Banks on CBS find it relatively easier to report the CTR. However other banks would have to ensure that the generation of CTR is a centralized activity and therefore their processes have to facilitate timely collation of data across all branches at one location so that reporting can be done.
  • Banks are required to incorporate the BSR code in the Branch file of the CTR. In case BSR is not available in case of new branches, banks may use a unique code other than BSR for the branch so that it is possible to identify records across the CTR files.

 

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