What changed
RBI clarified that cash transaction reporting by branches to the Principal Officer must be monthly, not fortnightly. For integrally connected cash transactions, banks must consider all individual cash transactions in an account during a calendar month where debit or credit summation exceeds ₹10 lakh, but need not report transactions below ₹50,000. Banks must also report forged/ counterfeit currency transactions to FIU-IND using the CCR format.
What it means for you
Banks must strengthen their transaction monitoring systems to detect suspicious patterns aligned with customer risk profiles. The monthly CTR deadline tightens reporting discipline, and the ₹10 lakh threshold for integrally connected transactions requires careful aggregation. Non-computerized branches must still feed data electronically via FIU-IND utilities, increasing operational burden but ensuring compliance.
What you must do
- Ensure all branches submit cash transaction details to the Principal Officer on a monthly basis, not fortnightly.
- Deploy or upgrade software to generate alerts for transactions inconsistent with customer risk categorization and updated profiles.
- File CTR electronically with FIU-IND by the 15th of the succeeding month; for non-computerized branches, use FIU-IND's editable utilities. STRs should be filed immediately when suspicion arises.
- Report all forged or counterfeit currency transactions to FIU-IND immediately using the CCR format (Annex II-III, with electronic data structure in Annex IV).
- Review and aggregate integrally connected cash transactions per account monthly, reporting only those where debit or credit sum separately exceeds ₹10 lakh, excluding individual transactions below ₹50,000.
Who it affects
State and Central Co-operative Banks, Principal Officers of co-operative banks, Branch managers handling cash transactions, Compliance and AML teams
What is the new deadline for submitting Cash Transaction Reports (CTR)?
CTR must be submitted to FIU-IND for every month by the 15th of the succeeding month. Branches must report to the Principal Officer on a monthly basis, not fortnightly.
How should banks handle integrally connected cash transactions for CTR?
Banks should consider all individual cash transactions in an account during a calendar month where either total debits or total credits exceed ₹10 lakh. However, individual transactions below ₹50,000 need not be reported in the CTR.
What should banks do if they have non-computerized branches?
The Principal Officer must manually collect transaction details from non-computerized branches and feed the data into an electronic file using the editable utilities provided by FIU-IND on their website.