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Cash Deposits Just Below the Reporting Line

RBSE SS Voc Banking · Put your knowledge to work in context.

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Cash Deposits Just Below the Reporting Line

At a mid-sized branch in Bhilwara, a clerk reviewing cash transactions notices that Shree Balaji Hardware, a proprietorship with a current account, has made 26 cash deposits between ₹4,50,000 and ₹4,90,000 each over the last three months, totalling ₹1.21 crore. Not one deposit crosses ₹10 lakh. The firm's stated business is retail hardware; its annual turnover declared at onboarding was ₹60 lakh. Asked about the source of the cash, the proprietor says, 'It is seasonal collection from contractors, I don't keep records of every bill.' The branch manager, who is ₹8 crore short of the branch's CASA target, says, 'He is a local businessman and a good customer; do not irritate him, and no report is needed since no deposit is above ₹10 lakh.' The same afternoon a walk-in customer arrives with ₹12,00,000 in cash, and the manager suggests making three receipts of ₹4,00,000 each so that 'the paperwork stays simple'.

1. Is the manager right that no report is needed because no single deposit crosses ₹10 lakh? Explain the aggregation rule and compute the position.

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The manager has confused 'no single receipt above ₹10 lakh' with the reporting rule.

  • The Cash Transaction Report aggregates cash deposits (and separately, cash withdrawals) for one customer over one calendar month, at a threshold of ₹10 lakh and above. It is not a per-receipt threshold.
  • The arithmetic: 26 deposits of ₹4.5-4.9 lakh over three months averages roughly ₹40 lakh a month - about four times the CTR threshold. A CTR is due for each of the three months, filed through the bank's Principal Officer to FIU-IND by the 15th of the following month.
  • The pattern is itself reportable: amounts deliberately kept just under ₹4.9 lakh, uniform and repeated, with no receipt crossing the line. That is the classic signature of structuring, and structuring is a red flag whether or not each individual receipt is below the threshold.
  • The turnover mismatch must be acted on: ₹1.21 crore in three months against a declared annual turnover of ₹60 lakh. The CDD record is now stale and the risk classification should move to high; 'I don't keep records of every bill' is not an adequate answer from a registered dealer at this cash volume.

So: CTR for all three months, a KYC refresh, and enhanced due diligence. Note fairly that hardware retail is a legitimately cash-heavy trade - that alone is not suspicion. The discipline is to judge the pattern, not the trade.

2. Should a Suspicious Transaction Report be filed? Give the reasoning, including the mitigating facts, and describe the process.

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Weighing the facts. (i) Cash-heavy trade - neutral. (ii) Twenty-six deposits of near-identical size just below ₹5 lakh - strongly suggestive of structuring. (iii) Cash volume four times the declared turnover - unexplained. (iv) No records and an evasive answer - an adverse factor. (v) No customer complaint, no adverse news, deposits made openly - a mitigating factor. On the totality, reasonable suspicion exists. The branch does not need proof of a predicate offence, only reasonable grounds to suspect.

Process:

  • File an STR through the bank's Principal Officer/designated director to FIU-IND. There is no minimum monetary threshold for an STR; it is independent of the CTR, and both are filed.
  • The designated officer decides and files. The branch does not file directly, and the customer is not told - tipping off is an offence.
  • Do not freeze the account or stop operations on your own. Continue normal banking, strengthen due diligence, and keep the records.
  • Document the decision and the reasons, whether the outcome is 'file' or 'do not file'. An unexplained non-filing is exactly what an inspection picks up.
  • Keep monitoring: further deposits, sudden transfers abroad, or a request to close the account should trigger a fresh assessment.

The manager's CASA target is not a factor that may be weighed in this decision.

3. The manager wants a ₹12 lakh deposit split into three receipts of ₹4 lakh. Assess that instruction and state what you do.

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Refuse, and put the refusal on record.

Why it is wrong. Accepting ₹12,00,000 as three receipts 'to keep the paperwork simple' is not a paperwork choice; it is designing transactions to stay below a threshold. That is structuring, and knowingly assisting such an arrangement is a serious offence under the Prevention of Money Laundering Act, independent of what the customer intended. It is also pointless: CTR aggregation is by customer and by month, so three receipts to the same PAN in the same month are aggregated anyway.

What to do:

  1. Accept the cash as one transaction, with proper CDD and the source of funds recorded where the amount or pattern warrants it.
  2. Do not carry out the split, and do not pass it to a colleague to do.
  3. Write a contemporaneous note - date, time, who instructed what - and send it to the Principal Officer/compliance and, if needed, the whistle-blower channel.
  4. Do not confront the manager publicly; the note and the escalation are your protection and the bank's.
  5. Remember that the branch's CASA target is irrelevant to the decision. Target pressure is the most common cause of these instructions, and it is not a defence for anyone involved.