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Introduction

The Bank Secrecy Act of 1970 (BSA) requires that financial institutions in the United States facilitate in assisting US government agencies to detect and prevent money laundering.

The BSA act requires that financial institutions file Currency Transaction Reports (FinCEN CTR) for cash transactions that exceed $10,000 that were performed during the same business day. The amount of $10,000 or more can be either in one transaction or in a conbination of many transactions. In addition, financial institutions are required to log Monetary Instrument Logs (MIL) for all cash purchases that total between $3,000 to $10,000 inclusive. Those logs must be kept on record at the financial institution, and produced at the request of examiners or auditors to verify compliance.

Any bank that wishes to designate a customer as an exempt person or exempt account for the purpose of CTR reporting must file a Designation of Exempt Person (DOEP) report.

SimpleOFAC FinCEN CTR automates the CTR and MIL creation, EFile generation to assist financial institutions in complying with the Fin CTR requirements above.

It has the following modules:

Daily processing​

  1. Load the customer(party), account and transaction data into staging tables.
  2. Agrgagate transactions by primary beneficiary, by conductor.
  3. Generate CTR and MIL reports.
  4. Genereate CTR and DOEP E-files and send to FinCEN.
  5. Load acknowlege files from FinCEN.

WorkItem (CTR, MIL and DOEP)​

This function is used by investigator to review those CTR, MIL and DOEP workitems and make decision on them.

Workflow​

It has a build-in configurable workflow for workitem, including the CTR workflow, MIL workflow and DOEP workflow.

Operations​

The above daily processing is normally implemented via batch scheduled jobs. This function allow admin user to proform the task via web interface (for easy testing). It also displays the processing status, along with EFile and Acknowledgement file status.

Online test drive​

FinCEN CTR online test drive: https://ctr.simpleofac.com

Use admin as login and !Qazxsw2 as password

Glossary​