Why are CTR and STR important in controlling money laundering risk?
Cash Transaction Report (CTR)
CTR (Cash Transaction Report) is a mandatory report that banks must submit to the Bangladesh Financial Intelligence Unit (BFIU) for all cash transactions — including online and ATM transactions — in a single day that amount to Tk. 10 lakh or above (or the equivalent in foreign currency) in any account, whether deposited or withdrawn.
CTR is important because:
- It creates a systematic record of large cash movements that may be used to layer or integrate illegally obtained funds.
- It enables BFIU to monitor patterns of large cash flows across the banking system and identify suspicious activity.
- It ensures accountability — each CTR is submitted monthly, and branches must retain records for at least 5 years.
- It deters money launderers who rely on cash-intensive transactions to disguise the origin of illicit funds.
Suspicious Transaction Report (STR)
STR (Suspicious Transaction Report) is a report that bank employees must submit immediately to the BFIU when they identify a transaction that is complex, abnormal, or appears to be linked to illegal activity — regardless of the transaction amount.
STR is important because:
- Money launderers often structure transactions to stay below the CTR threshold. STR captures suspicious patterns that CTR would miss.
- It empowers front-line bank staff to act as the first line of defence against money laundering.
- It provides BFIU with intelligence on potential money laundering, terrorist financing, and trade-based money laundering (TBML).
- It is legally required under the Money Laundering Prevention Act 2012 and Anti-Terrorism Act 2013 — failure to report can result in severe penalties for the bank and the officer involved.
Together, CTR and STR
CTR and STR together create a comprehensive transaction monitoring system. CTR monitors volume — catching large cash flows. STR monitors behaviour — catching suspicious patterns regardless of size. Together, they form the core of a bank’s AML compliance framework.
