Any person who contravenes Section 4A of the AMLA commits an offence and shall on conviction be liable to a fine of not more than 5 times the aggregate sum or value of the transaction at the time of the offence was committees or to imprisonment for a term not exceeding 7 years or to both.

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.

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).