Currency Transaction and High-Value Cash Reporting
This domain tests high-value cash reporting, which is a separate control from suspicious transaction reporting. The exam expects you to know the threshold, aggregation logic, identification duties, and why a CTR is not an accusation.
Core rules
- Korean financial institutions report cash transactions of KRW 10 million or more, or the foreign-currency equivalent, to KoFIU.
- Aggregation generally applies to cash transactions by the same customer at the same financial institution on the same business day.
- The institution must identify and verify the customer and record the details required by the SFIA and supervisory rules.
- A CTR is objective and threshold-based; it does not require suspicion. An STR is suspicion-based and has no won threshold.
- Structuring, or splitting cash to stay below the threshold, is itself a red flag and may require an STR.
Worked example
A customer deposits KRW 6 million in cash at 10:00 and KRW 5 million in cash at 15:00 at the same bank branch. The total for the same customer, same institution, and same business day is KRW 11 million, so a high-value cash report is required. If the customer gives inconsistent explanations for the cash source, the bank should also consider an STR.
Traps
Do not use the USD 10,000 travel declaration threshold for domestic CTRs. Do not assume a CTR alone satisfies suspicion obligations. Do not ignore same-day aggregation across tellers or branches of the same institution.