What changed
RBI clarified that integrally connected cash transactions are determined by aggregating all cash debits or credits in an account during a calendar month exceeding ₹10 lakh, with individual transactions below ₹50,000 not required to be indicated in CTR. Banks must now submit CTR monthly (not fortnightly) to the Principal Officer, who files to FIU-IND by the 15th of the succeeding month. Counterfeit currency transactions must be reported immediately via CCR format, and transactions involving forgery of valuable security or documents may be reported in plain text form.
What it means for you
RRBs must tighten transaction monitoring by implementing software that alerts on inconsistencies with customer risk profiles. Non-computerized branches must manually feed data into electronic CTR/STR utilities. The clarified aggregation rule reduces ambiguity in reporting connected transactions, but increases compliance burden for high-volume accounts. Failure to file electronic reports to FIU-IND may invite regulatory scrutiny.
What you must do
- Ensure all branches submit cash transaction data monthly (not fortnightly) to the Principal Officer for CTR filing by the 15th of the next month.
- Deploy or upgrade software to generate alerts for transactions inconsistent with customer risk categorization and updated profiles.
- For non-computerized branches, use FIU-IND's editable electronic utilities to compile and file CTR/STR.
- Report counterfeit currency transactions immediately to FIU-IND using the prescribed CCR format (Annex II and III) and also report transactions involving forgery of valuable security or documents in plain text form.
- Review customer risk profiles periodically and ensure transaction monitoring software throws alerts for inconsistencies.
Who it affects
Regional Rural Banks (RRBs), Principal Officers of RRBs, Branch managers handling cash transactions, Compliance and AML teams at RRBs
What is the threshold for reporting integrally connected cash transactions?
Banks must consider all individual cash transactions in an account during a calendar month where either total debits or total credits exceed ₹10 lakh. However, details of individual transactions below ₹50,000 need not be indicated in the CTR.