What is Cash Threshold report (CTR)
CTR refers to cash transactions exceeding RM50,000 (or any other amount advised) involving physical currencies (domestic or foreign currency) and bearer negotiable instruments such as travellers’ cheques but excludes bank drafts, cheques, electronic transfers or fixed deposit rollovers or renewals. These include transactions involving withdrawal of cash from accounts or exchange of bearer negotiable instruments for cash.
The requirements for CTRs are applicable to single or multiple cash transactions within the same amount specified in a day. Where there are deposit and withdrawal transactions, the amount must be aggregated. For example, a deposit of RM40,000 and a withdrawal RM20,000 must be aggregated to the amount of RM60,000 and hence, must be reported if it exceeds the amount specified.
Section 4A of the AMLA set out the offence of structuring transactions so as to avoid reporting CTR. A structuring involves splitting transactions into separate amounts under RM50,000 per day to avoid CTR transaction reporting requirements under the AMLA.
Circular on reduced threshold for CTR (effective 1st January 2019)
On the 30th October 2018 at the 10th International Conference On Financial Crime and Terrorism Financing, Governor's during her keynote address, had announced that the 'Cash Threshold Reporting' ('CTR') requirement will be reduced from RM50,000 and above in a day to RM25,000 and above in a day effective 1st January 2019. Attached below are the relevant Amendment Orders which were gazetted on the 28th December 2018 together with Circular issued by the Bank, on the new 'CTR' threshold.
Who is required to report a CTR?
To date, CTR reporting obligations are imposed on banking institutions and the licensed casino only.
How to report a CTR?
Reporting of CTR is undertaken electronically via the Financial Intelligence System (FINS).