Bank Secrecy Act
International Transportation of Currency or Monetary Instruments Reporting
Objective. Assess the bank’s compliance with statutory and regulatory requirements for the reporting of international shipments of currency or monetary instruments.
1. Determine whether the bank has (or has caused to be) physically transported, mailed, or shipped currency or other monetary instruments in excess of $10,000, at one time, out of the United States, or whether the bank has received currency or other monetary instruments in excess of $10,000, at one time, that has been physically transported, mailed, or shipped into the United States.
2. If applicable, review the bank’s policies, procedures, and processes for filing a Report of International Transportation of Currency or Monetary Instruments (CMIR) (FinCEN Form 105) for each shipment of currency or other monetary instruments in excess of $10,000 out of or into the United States (except for shipments sent through the postal service, common carrier, or to which another exception from CMIR reporting applies).
3. On the basis of a risk assessment, prior examination reports, and a review of the bank’s audit findings, select a sample of transactions conducted after the previous examination to determine whether the bank has appropriately completed, submitted, and retained copies of the CMIR forms.
4. On the basis of examination procedures completed, including transaction testing, form a conclusion about the ability of policies, procedures, and processes to meet regulatory requirements associated with CMIRs.
5. On the basis of the previous conclusion and the risks associated with the bank’s activity in this area, proceed to expanded examination procedures, if necessary.