Per section 1010.415 of the FinCEN regulations, credit unions are required to verify the identity of persons using “currency” (i.e. cash) to purchase monetary instruments in amounts between $3,000 and $10,000 and to maintain records of all such sales. This log is referred to as a Monetary Instrument Log.
The core does not offer a canned report of such sales; however, you can take advantage of Trackers to create such a log.
We recommend you use Tool #984 Work Daily BSA/CTR Activity, a dashboard that contains all cash transactions above $3k, to monitor your cash logs daily and look to the member’s account to see if a same day monetary instrument was cut on the member’s account.
If there is evidence of a same day monetary instrument, best practice is to update the member’s Audit Tracker using Memo Type MI (monetary instrument) and state the following: amount of cash in, amount of monetary instrument, monetary instrument number (check number), date of transaction, and employee that conducted the transaction.
Using Tool #664 Print Member Trackers, you can filter the Tracker type to AT (audit tracker) and Memo type to MI (monetary instrument) for dates selected. Check the Print Conversation Detail box option at the bottom of the screen to produce a report that lists all of these trackers, providing your Monetary Instrument Log.
For more information on how to use Tool #984 to review cash logs, please see the AuditLink training video in the Related Links below!