United States General Accounting Office

GAO Report to the Committee on Banking,

Housing, and Urban Affairs, U.S. Senate,

and the Committee on Banking and

Financial Services, House of

Representatives

July 1995 MONEY

LAUNDERING

Stakeholders View

Recordkeeping

Requirements for

Cashier’s Checks As

Sufficient

GAO/GGD-95-189

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-259797 

July 28, 1995

The Honorable Alfonse M. D’Amato

Chairman

The Honorable Paul S. Sarbanes

Ranking Minority Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

The Honorable Jim Leach

Chairman

The Honorable Henry B. Gonzalez

Ranking Minority Member

Committee on Banking and Financial Services

House of Representatives

The Bank Secrecy Act of 1970 (BSA), as amended, requires that financial

institutions1

 maintain certain records and reports for criminal, tax, or

regulatory proceedings, including investigations of money laundering. The

Money Laundering Suppression Act of 1994 required us to determine

whether additional recordkeeping requirements, such as making copies of

cashier’s checks retrievable by customer information, should be imposed

on those financial institutions issuing cashier’s checks. Specifically, for

financial institutions issuing cashier’s checks, we agreed with the

Committees to (1) identify the current recordkeeping requirements and

(2) determine the views of federal government and financial industry

officials on the need for additional recordkeeping requirements.

To identify current recordkeeping requirements, we reviewed pertinent

provisions of BSA and federal regulations for issuing and maintaining

records for cashier’s checks and other monetary instruments. To

determine federal and industry officials’ views, we discussed with

Treasury, Federal Bureau of Investigation (FBI), federal financial

regulatory agency, and financial industry officials (1) the usefulness of the

currently required records and (2) the need for additional recordkeeping

requirements. (App. I contains the details of our objectives, scope, and

methodology.)

1

The Department of the Treasury regulations implementing BSA define the term “financial institution”

to include banks, federally regulated securities brokers, currency exchange houses, funds transmitters,

check cashing businesses, and persons subject to supervision by state or federal bank supervisory

authority.

Page 1 GAO/GGD-95-189 Money Laundering
B-259797 

Background Criminal enterprises generate enormous amounts of cash. To make them

easier to conceal and transport, some criminal enterprises convert illicit

cash proceeds into monetary instruments, such as traveler’s checks,

money orders, or cashier’s checks. To combat this practice, Treasury, in

implementing the requirements of BSA, requires financial institutions to

report and maintain records of certain financial transactions. These

reporting and recordkeeping requirements, which vary by the amount of

the financial transaction, are intended to (1) assist law enforcement

officials in criminal, tax, or regulatory investigations and proceedings and

(2) help law enforcement officials identify suspicious and unusual

financial transactions.

To further assist law enforcement officials in their efforts to combat

money laundering, financial institutions are urged by Treasury and federal

financial industry regulators to develop an effective know-your-customer

program. Know-your-customer programs are designed to encourage

employees of financial institutions to become familiar with the banking

practices of their customers so that they can recognize transactions that

are outside the normal course of a customer’s business practices and

report them as suspicious to the appropriate federal oversight agencies.

Results in Brief Treasury regulations implementing the Bank Secrecy Act require financial

institutions, when issuing or exchanging cashier’s checks for currency, to

(1) file a currency transaction report for financial transactions involving

more than $10,000 in currency, (2) capture and retain purchaser

information for transactions of $3,000 to $10,000, (3) retain copies of

cashier’s checks for amounts over $100, and (4) maintain a record of

certain check transactions exceeding $100. In addition, Treasury and the

financial industry have been working together to place more emphasis on

the need for financial institutions to (1) develop effective

know-your-customer programs and (2) report suspicious financial

transactions.

Federal regulators, financial industry officials and advisory groups, and

law enforcement officials with whom we spoke or who had expressed

their views in published documents agreed that current recordkeeping and

reporting requirements—together with the development of effective

know-your-customer programs and the reporting of suspicious financial

transactions—are sufficient requirements for those financial institutions

issuing cashier’s checks. They agreed that imposing additional

recordkeeping requirements, such as one that would specifically require

Page 2 GAO/GGD-95-189 Money Laundering
B-259797 

financial institutions to have systems to retrieve copies of cashier’s checks

by customer name or account number, would not add to the effectiveness

of the current BSA recordkeeping requirements.

Current

Recordkeeping

Requirements for

Cashier’s Checks

In implementing BSA requirements, Treasury requires financial institutions

to file a currency transaction report for each deposit, withdrawal,

exchange of currency, or other payment or transfer by, through, or to

financial institutions, that involves more than $10,000 in currency. This

requirement includes cashier’s checks.

Because concern existed that money launderers were making financial

transactions in amounts of $10,000 or less to evade the BSA reporting

requirements, Congress in 1988 amended the BSA to require financial

institutions to capture, verify, and retain a record of the identity of the

purchasers of cashier’s checks and certain other monetary instruments for

currency of $3,000 or more. The Secretary of the Treasury also determined

that it would be useful to criminal investigators to require banks to retain

(1) either the original or a copy of certain checks, including cashier’s

checks, exceeding $100 and (2) records prepared or received in the

ordinary course of business that would be needed to reconstruct a

customer’s deposit account and to trace through the bank’s processing

system a check in excess of $100 deposited in an account. Treasury

requires that these records be retained for 5 years and be made readily

available to the Secretary of the Treasury upon request.

In addition, after it had received inquiries from financial institutions about

whether suspicious transactions should be reported and what information

should be reported, the Department of the Treasury issued Administrative

Ruling 88-1 on June 22, 1988. This ruling encouraged but did not require

financial institutions to report transactions that might be “...relevant to a

possible violation of the BSA or its regulations or indicative of money

laundering or tax evasion” to the local office of the Internal Revenue

Service’s (IRS) Criminal Investigation Division (CID). Also in 1988, the

Comptroller of the Currency Regulation 12 C.F.R. section 21.11 and

corresponding regulations issued by the other bank regulatory agencies

required financial institutions to report suspected money laundering

and/or BSA violations and provide a copy of these reports to the local office

of IRS’ CID. A 1992 amendment to BSA prohibits financial institutions from

Page 3 GAO/GGD-95-189 Money Laundering
B-259797 

notifying persons involved in suspicious transactions that the transaction

had been reported to IRS.

2

Table 1 summarizes the current recordkeeping and reporting requirements

for cashier’s checks.

Table 1: Federal Recordkeeping and Reporting Requirements for Transactions Involving Cashier’s Checks

Transaction amount Type of requirement Description

Over $100 Recordkeeping and retention Treasury requires financial institutions to retain (1) copies or originals of

cashier’s checks and (2) a record of transactions associated with deposit

accounts that involved check transactions over $100. These records and copies

are to be retained for 5 years.

$3,000-$10,000 Recordkeeping and retention In addition to the requirements noted above for transactions exceeding $100,

financial institutions are required to capture, verify, and retain information on the

identity of the purchasers of cashier’s checks for $3,000 to $10,000. These

records are required to be retained for 5 years.

Over $10,000 Currency transaction reporting 

Recordkeeping and retention

IRS Form 4789 is used to report to IRS transactions involving the physical

transfer of currency in excess of $10,000. 

Same requirement as noted above for cashier’s checks exceeding $100.

Any amount Suspicious transaction

reporting

Financial institutions are encouraged by Treasury and required by financial

industry regulators to report abnormal or suspicious transactions of any amount

to IRS and the appropriate financial industry regulator. Various forms and

methods of reporting are used.

Sources: GAO review of pertinent provisions of BSA and federal financial industry regulations and

administrative rulings.

In 1990, Treasury developed a regulation to implement the 1988

amendment to BSA that required financial institutions to capture, verify,

and retain information on the identity of purchasers of cashier’s checks

and other monetary instruments. After considering several alternative

recordkeeping requirements, including a requirement that information be

kept on copies of monetary instruments and be retrievable by copy,

Treasury concluded that maintaining a log3

 of the BSA-required information

would be the most effective method of keeping the information.

Imposing a specific requirement that financial institutions maintain the

BSA-required information on copies of monetary instruments was viewed

as too burdensome because, according to Treasury officials, it would

2

Our report on suspicious-transaction reporting discusses several methods that are currently used by

financial institutions to report suspicious transactions. See Money Laundering: Needed Improvements

for Reporting Suspicious Transactions Are Planned (GAO/GGD-95-156, May 30, 1995).

3

A log is a means of recording information in one place to make the information more easily

accessible.

Page 4 GAO/GGD-95-189 Money Laundering
B-259797 

require financial institutions to sift through thousands of documents

located at various branches to comply with a Treasury request for

purchaser information. Treasury also took into consideration that financial

institutions keep different kinds of records for each type of monetary

instrument and decided that a log would make the BSA information more

easily accessible by both the financial institutions and the Treasury

Department.

Treasury’s August 1990 regulation requiring the log did not specify the

form in which the log was to be maintained. In addition, the 1990

regulation allowed for but did not require that a separate log be

maintained for each type of monetary instrument.4

 Treasury anticipated

that it would request copies of logs by date of issuance rather than by

customer name, account number, or type of monetary instrument.

Subsequent to the institution of the log requirement, Treasury found that

the BSA information that was being logged on the sale or exchange of

cashier’s checks for currency was seldom used by law enforcement

officials and federal regulators to initiate or conduct money laundering

investigations. Compliance with the log requirement was found to impose

an expensive and time-consuming burden on the financial industry. As a

result, in October 1994, Treasury rescinded the log requirement.5

 Treasury

now permits financial institutions to maintain the required BSA information

in any format they choose, as long as the information can be readily

retrieved at the request of the Secretary of the Treasury.

Views of Federal

Regulatory, Financial

Industry, and Law

Enforcement Officials

Federal regulators, financial industry officials and advisory groups, and

law enforcement officials with whom we spoke or who had expressed

their views in published documents agreed that the rescinding of the log

requirement that was associated with current BSA recordkeeping

requirements and the renewal of emphasis on having financial institutions

(1) develop effective know-your-customer programs and (2) report

suspicious financial transactions, are sufficient requirements for financial

institutions issuing cashier’s checks. In addition, they agreed that imposing

additional recordkeeping requirements, such as one that would

specifically require financial institutions to retrieve copies of cashier’s

checks by customer name or account number, would not add to the

effectiveness of the current BSA recordkeeping requirements.

4

In addition to cashier’s checks—bank checks, bank drafts, money orders, and traveler’s checks were

included in the scope of the log requirement.

5

59 Fed. Reg. 52,250 (1994).

Page 5 GAO/GGD-95-189 Money Laundering
B-259797 

Previously Imposed

Recordkeeping Log

Requirement Was Not

Beneficial

Federal regulators, financial industry officials and advisory groups, and

law enforcement officials with whom we spoke or who had expressed

their views in published documents supported Treasury’s decision to

rescind the log requirement for cashier’s checks and other monetary

instruments. Reasons cited included the time and effort it took to retrieve

the required BSA information on specific purchasers, the limited usefulness

of the data retrieved, and the expense associated with maintaining the

data.

In 1993, Treasury formed a money laundering task force to consider ways

to reduce the regulatory burden of complying with BSA while enhancing

the utility of the information collected. In 1994, the task force concluded

that the BSA information that financial institutions were required to

maintain in logs had been infrequently requested and used by law

enforcement officials. In addition, the task force and representatives of the

financial services industry found that compliance with the log requirement

imposed an expensive and time-consuming burden on financial

institutions when weighed against more immediate leads in the hands of

law enforcement officials, such as reports of suspicious transactions that

were being sent directly to IRS.

Criminal investigators from IRS and the FBI said that, because of other leads

and the ease of utilizing information obtained from direct reporting of

suspicious criminal activities, including suspicious-transaction reports, the

logged BSA data on the sale or exchange of monetary instruments were

used infrequently. They said that the logged BSA information was used on a

limited basis, primarily to build a stronger case against a suspect or for

further investigation or research.

Representatives of financial institutions said that they found the log

requirement to be costly and burdensome. To avoid the requirement, some

financial institutions prohibited the direct sale of monetary instruments

for cash to both deposit and nondeposit customers. Under this policy,

customers were required to deposit cash into an account from which a

financial institution could then issue a withdrawal to pay for the monetary

instrument.6

 Many bankers had indicated their preference for policies

prohibiting the sale of monetary instruments for cash because this

lessened the possibility of errors and omissions on the logs and eliminated

the additional paperwork created by the log requirement.

6

Treasury advised banks that such a policy did not violate BSA and that implementing such a policy

was within the bank’s discretion. However, Treasury did require the adoption of a written policy and

formal written procedures for implementing it. Also, Treasury required that the policy apply to all

deposit customers without exception.

Page 6 GAO/GGD-95-189 Money Laundering
B-259797 

The American Bankers Association estimated in October 1994 that the

elimination of the log requirement could save the financial industry about

$1 million a year in compliance costs and ease the administrative burden

on financial institutions.

Current Recordkeeping

and Reporting

Requirements Viewed As

Sufficient

Federal regulators, financial industry officials and advisory groups, and

law enforcement officials with whom we spoke or who had expressed

their views in published documents agreed that increased emphasis is

currently being placed on developing effective know-your-customer

programs and suspicious-transaction reporting, that banks are required to

retain copies of certain monetary instruments, and that financial

institutions are required to obtain purchaser identifying information. They

further agreed that these requirements are sufficient for assisting law

enforcement officials in their efforts to detect and further investigate the

use of monetary instruments to launder money.

Treasury consulted with a BSA advisory group7

 composed of 30

representatives from the financial services industry, trades, businesses,

and federal and state governments. Treasury concurred with the BSA

advisory group’s conclusion that financial institutions’ resources could be

more effectively used to assist law enforcement officials if more emphasis

were placed on (1) developing effective know-your-customer programs

and (2) reporting suspicious financial transactions to the appropriate

regulatory agencies. The American Bankers Association also agreed with

this conclusion.

Treasury and federal financial regulators have increased their efforts to

alert financial institutions to be more aware that the institutions may be

misused by criminals who engage in financial transactions to conceal

illegal proceeds and avoid federal currency transaction reporting

requirements. Financial institutions are being encouraged to become more

familiar with the banking practices of their customers—commonly

referred to as the know-your-customer program—so that transactions that

are outside the norm can be readily identified and reported to appropriate

regulatory agencies as suspicious.

Treasury expects to issue federal guidelines on developing

know-your-customer programs and reporting suspicious transactions in

1995. In the absence of such guidelines, federal bank regulators and

7

A 1992 amendment to BSA required Treasury to establish a BSA advisory group to advise the

Secretary of the Treasury on how to modify reporting requirements to enhance law enforcement and

inform the private sector on the uses of reported information.

Page 7 GAO/GGD-95-189 Money Laundering
B-259797 

financial industry groups have for some time provided guidance to their

members either in writing or through seminars that address the

importance of know-your-customer programs and suspicious-transaction

reporting. These guidelines and seminars provided tips to financial

institutions for detecting the use of cashier’s checks and certain other

monetary instruments to launder money.8

 Appendix II provides

information on guidance provided by the three major bank regulatory

agencies and on money laundering seminars held by financial industry

groups to inform their members.

Law enforcement officials responsible for combating money laundering

activities with whom we spoke said that in light of the increased emphasis

being placed on the development of know-your-customer programs and

the reporting of suspicious transactions, no additional recordkeeping

requirements are needed beyond those that are already in place. IRS and FBI

criminal investigators said that they support the efforts of federal

regulators to encourage financial institutions to place more emphasis on

reporting suspicious transactions. These law enforcement officials said

that current efforts to promote direct reporting of suspicious transactions

would be more beneficial to them than searching through logs of

information, because direct reporting would provide a more immediate

and direct lead to criminal investigators. They also said that the increased

emphasis on developing know-your-customer programs and reporting

suspicious transactions, together with the ongoing requirement that

financial institutions retain information on purchasers of monetary

instruments, should improve law enforcement’s ability to detect and

further investigate the use of monetary instruments to launder money.

Conclusion Federal regulators, financial industry and advisory groups, and federal law

enforcement officials with whom we spoke or who had expressed their

views in published documents agreed that current recordkeeping

requirements for cashier’s checks—together with the renewed emphasis

being placed on the development of effective know-your-customer

programs and suspicious-transaction reporting requirements—are

sufficient means for assisting law enforcement officials in their efforts to

combat the use of cashier’s checks and certain other monetary

instruments to launder money.

8

Results from a 1990 American Bankers Association survey showed that 86 percent of the banking

industry had established know-your-customer guidelines.

Page 8 GAO/GGD-95-189 Money Laundering
B-259797 

Agency Comments In June 1995, we requested comments on a draft of this report from the

Secretary of the Treasury or his designee, the Commissioner of IRS or her

designee, and the American Bankers Association. In written responses, the

Director of Treasury’s Financial Crimes Enforcement Network, the IRS

Assistant Commissioner of Criminal Investigations, and the Senior Federal

Counsel on Government Relations and Retail Banking of the American

Bankers Association all agreed with the information presented and the

conclusion reached.

We are sending copies of this report to the Secretary of the Treasury, the

Director of Treasury’s Financial Crimes Enforcement Network, the

Commissioner of Internal Revenue, the IRS Assistant Commissioner of

Criminal Investigations, the Attorney General, the Chief of the FBI’s

Economic Crimes Unit, and other interested parties. We will also make

copies available to others upon request.

This report was prepared under the direction and guidance of Chas.

Michael Johnson, Evaluator-in-Charge. Please contact me at (202) 512-8777

if you have any questions concerning this report.

Laurie E. Ekstrand

Associate Director, Administration

 of Justice Issues

Page 9 GAO/GGD-95-189 Money Laundering
Appendix I 

Objectives, Scope, and Methodology

As agreed with the Committees, we limited the scope of our review to

(1) identifying current recordkeeping requirements and (2) determining

the views of federal government and financial industry officials on the

need for additional recordkeeping requirements for financial institutions

issuing cashier’s checks.

To familiarize ourselves with how cashier’s checks are issued and to

identify recordkeeping and reporting requirements imposed on financial

institutions issuing cashier’s checks, we reviewed pertinent provisions of

the Bank Secrecy Act, relevant federal rules and regulations, and

published material such as financial and legal industry reports on BSA

compliance. We also interviewed officials from the Department of the

Treasury’s Financial Crimes Enforcement Network and IRS’ Criminal

Investigation Division (CID) to obtain their views on the level of

compliance with these requirements and the need for additional

requirements.

We obtained the views of the Senior Federal Counsel on Government

Relations and Retail Banking of the American Bankers Association on the

cost and impact of current, previous, and proposed recordkeeping and

reporting requirements for cashier’s checks. We also discussed the use of

these logs by law enforcement officials and obtained the American

Bankers Association’s views on whether additional recordkeeping and

reporting requirements for cashier’s checks are needed.

We met with law enforcement officials of IRS’ CID and the FBI’s Economic

Crimes Unit to ascertain what problems, if any, they may have with

current, previous, and proposed recordkeeping and reporting

requirements. We also discussed whether improvements are needed to

assist them in their efforts to combat the use of cashier’s checks and other

monetary instruments to launder money.

We consulted with officials from the Banking and Supervision units of the

Federal Reserve Board (FRB), Office of the Comptroller of the Currency

(OCC), and Federal Deposit Insurance Corporation (FDIC) in Washington,

D.C., to obtain their views on current, previous, and proposed

recordkeeping and reporting requirements and to identify efforts

undertaken by the banking industry to ensure compliance with BSA and

regulatory requirements. We discussed steps taken by these bank

regulators to combat the use of cashier’s checks and other monetary

instruments to launder money and reviewed relevant agency documents

relating to detecting and deterring money laundering.

Page 10 GAO/GGD-95-189 Money Laundering
Appendix I 

Objectives, Scope, and Methodology

We could not address the extent to which cashier’s checks have been

involved in money laundering schemes because no statistical data existed.

We did our review in accordance with generally accepted government

auditing standards from November 1994 through March 1995 at the

Department of the Treasury in Washington, D.C.; at IRS’ CID in Washington,

D.C., and Alexandria, VA; at the FBI in Washington, D.C.; and at various

financial and regulatory organizations in Washington, D.C.

Page 11 GAO/GGD-95-189 Money Laundering
Appendix II 

Guidance Provided by Federal Bank

Regulatory Agencies and Financial Industry

Groups for Detecting the Use of Cashier’s

Checks to Launder Money

In the absence of standard know-your-customer guidelines from Treasury,

federal bank regulators1

 have issued guidance that addresses the

importance of developing effective controls to detect and report, among

other things, the suspected use of cashier’s checks to launder money. For

example, OCC has periodically reissued a pamphlet to national banks

entitled Money Laundering: A Banker’s Guide to Avoiding Problems. In a

June 1993 update of this pamphlet, OCC reemphasized that

know-your-customer policies are a bank’s most effective weapon against

being used unwittingly to launder money. The OCC pamphlet stated that

knowing your customers includes requiring appropriate identification and

being alert to unusual or suspicious transactions, including those involving

cashier’s checks or other monetary instruments. The OCC pamphlet also

highlighted suspicious activities that bank employees should look for and

included a discussion of ways bank customers may attempt to avoid BSA

reporting requirements.

In March 1991, FDIC provided guidance to state nonmember banks on

reporting suspicious transactions. The guidance encouraged these banks

to be alert to the possibility that they may be misused by persons who are

intentionally attempting to evade the BSA reporting requirements or who

are engaging in transactions that may involve money laundering.

In January 1995, FRB provided guidance to its member banks outlining the

importance of know-your-customer programs and the detection and

reporting of suspicious transactions. FRB guidance to its members

emphasized that it is imperative that financial institutions adopt

know-your-customer guidelines or procedures to ensure the immediate

detection and identification of suspicious activity at the institution. FRB’s

January 1995 guidance noted that an integral part of an effective

know-your-customer policy is to have comprehensive knowledge of the

transactions carried out by a customer in order to be able to identify

transactions that are inconsistent.

In addition, informative publications have been issued and various money

laundering conferences and seminars have been held to discuss new

developments and changes in the oversight of criminal activities to

launder money. These efforts have involved federal regulators, law

enforcement and financial industry groups, and trade associations. For

example, the American Bankers Association, in conjunction with the

American Bar Association’s Criminal Justice Section, periodically holds

1

Federal bank regulators are responsible for, among other things, ensuring that financial institutions

apprise federal law enforcement authorities of any violation or suspected violation of a criminal

statute, including money laundering.

Page 12 GAO/GGD-95-189 Money Laundering
Appendix II 

Guidance Provided by Federal Bank

Regulatory Agencies and Financial Industry

Groups for Detecting the Use of Cashier’s

Checks to Launder Money

Money Laundering Enforcement Seminars to highlight Treasury initiatives

in the money laundering area. An October 1994 seminar, sponsored by the

American Bankers Association and the American Bar Association,

addressed a proposal for mandatory suspicious-transaction reporting and

the need for banks to develop know-your-customer programs. The seminar

also included a discussion on the use of monetary instruments to launder

money. The American Bankers Association estimated that it alone had

trained 75,000 to 100,000 bankers in the past 8 years through these

seminars.

The following are some examples highlighted in the guidance provided to

financial institutions of activities that might be considered inconsistent

with a customer’s normal business activity:

• an account that shows frequent deposits of large bills for a business that

generally does not deal in large amounts of cash;

• accounts with very large volumes of deposits in cashier’s checks, money

orders, and/or wire transfers when the nature of the account holder’s

business does not justify such activity; and

• deposits of numerous checks but rare withdrawals of currency for daily

operations.

The following are some examples of other customer activities that may

trigger suspicious-transaction reports:

• a reluctance on the part of the customer to produce identification or

provide personal background information when opening an account or

purchasing monetary instruments above a specified threshold,

• a customer’s taking back part of the currency to reduce the purchase to

below $3,000 after becoming aware of the financial institution’s

recordkeeping requirement, and

• a customer’s coming into the same institution on consecutive or

near-consecutive business days to purchase cashier’s checks in amounts

of less than $3,000.

(182008) Page 13 GAO/GGD-95-189 Money Laundering
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