Beyond reporting, currency and financial recordkeeping rules impose specific obligations on what institutions retain and what they transmit.

Currency transaction reporting. Cash transactions above the threshold, by or on behalf of the same person on the same business day, must be reported with aggregation. Exemption procedures exist for qualifying businesses and must be documented and reviewed.

Structuring. Breaking transactions to evade reporting is an offense, and institutions must not assist. Advising a customer how to avoid a report is distinct from explaining that a report will be filed, which is permitted.

Monetary instrument logs. Sales of cashier’s checks, money orders and traveller’s checks for cash within a stated range require recorded identification.

Funds transfer recordkeeping. Originator and beneficiary information must be obtained and retained for transfers above the threshold.

The travel rule requires certain of that information to be included in the transmittal order sent to the next financial institution in the chain. Incomplete straight-through processing that drops fields is a recurring examination finding.

Retention. Five years is the general standard, measured from the record’s creation or the account’s closure depending on the record type.

Cross-border reporting of currency and instruments applies to customers, and institutions should be able to explain the obligation without giving advice on avoiding it.