[TomGuy]

the cash transaction amount that triggers the reporting requirement is $10K, not, as Toobin stated, $5K.

IIRC, the old figure was $10k, but under the Patriot Act, the figure was revised to $5k.

Anti-Money Laundering Initiatives Under the USA Patriot Act

Proposed Rule for Broker Dealers Broader than those for Banks. For reasons that have not been disclosed, the proposed rule for broker-dealers does not exactly parallel the existing rule for depository institutions and, in many ways, the proposed rule includes reporting requirements that are broader than the requirements for banks. For example, under the existing rules, a depository institution must submit a SAR for any activity that involves at least $5,000 and: (i) any known or suspected violation of federal law; (ii) a suspicious transaction related to money laundering; or (iii) a violation of the BSA. Under the proposed rule applicable to broker-dealers, the reporting requirement is triggered by "any suspicious transaction relevant to a possible violation of law or regulation."17 Thus, a broker-dealer would be required to report a possible violation of state law, whereas a depository institution would not have such a requirement, assuming the violation did not involve suspicious activity relating to money laundering or a violation of the BSA. There are other differences between the two reporting requirements and these inconsistencies have been identified during the comment period for the proposed rule, which ended March 1, 2002.18 The final regulations are due no later than July 7, 2002 and will take effect 180 days after publication.

[reformed_dem]

No. A CTR is required for cash in or out over $10,000. That has not changed. If there are frequent large cash transactions below $10,000, then an SAR is filed.

[rabscuttle385]

IIRC, the old figure was $10k, but under the Patriot Act, the figure was revised to $5k.

Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) are different. A CTR must be filed if total cash transactions go over $10,000 in a single business day. There are also forms to be filed for cash purchases of negotiable instruments such as official checks and money orders. SAR filings can be triggered by any suspicious activity.

In Mr. Spitzer's case, calling to ask that his name be removed from wire transfers warranted filing a SAR. That, and the folks on Wall Street that he pissed off were probably the same folks with whom he was banking. Basically, it's Spitzmas in March.