1. Cash Handling Compliance Protocols
Transaction Thresholds and Actions
Dual Control Principle
- All transactions above LKR 5M require two authorized signatories
- Cash counts must be verified by supervisor
- System overrides require Principal Officer approval
2. Transaction Monitoring & Reporting
Structuring Detection
Definition: Breaking large transactions into smaller amounts to avoid reporting thresholds
Example Scenario:
- Customer makes 5 transactions of LKR 1.9M within 2 hours
- Total value: LKR 9.5M (below CTR threshold)
- Required Action: File STR for suspected structuring
CTR Filing Timeline
3. Customer Identification at Cage
Document Verification Standards
- Sri Lankan NICs: Check hologram, UV features, chip data
- Foreign Passports: Verify MRZ, biographical page, visa validity
- Additional Verification: Cross-check with watchlists in real-time
High-Risk Customer Protocol
- Identification: PEP, high-risk jurisdiction, cash-intensive business
- Escalation: Immediate notification to Principal Officer
- Documentation: Complete EDD package before transaction processing
- Monitoring: Enhanced surveillance during visit
4. Source of Funds Verification
Acceptable Documentation
5. Currency Control Measures
Counterfeit Detection Protocol
Cash Handling Security
- Regular cash counts with surveillance present
- Secure transportation for bank deposits
- Limitation on cash kept in cage overnight
- Random audits by internal control team
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