Threshold transaction disclosures: access on demand through latent disclosure rather than reporting

Abstract

Distinguishes between the two normal methods of reporting suspected cases of money laundering to the authorities, usually a financial intelligence unit (FIU): a suspicious transaction report (STR) or a cash transaction report (CTR), the latter occurring when the amount of cash exceeds the threshold figure. Points out problems in CTR, mainly that it is only relevant at the placement stage of money laundering. Considers a system of threshold transaction disclosures as a possible compromise; this would cover all transactions over the threshold, not just cash. Suggests an “access on demand” system as a hybrid variety of threshold reporting. Concludes that threshold disclosure can be an effective low‐cost solution to the evolving practice of money laundering.