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by hakfoo 1379 days ago
Is mandatory reporting a good idea, though?

I feel like the signal-to-noise ratio must be terrible, especially as inflation gradually lowers the meaning of a $10,000 reporting limit. Selling a used car is enough to trigger a reportable amount of cash.

I'd think what we need is less magic numbers, and instead a better training/reporting ecosystem that insulates people with good intentions but gives them the right tools to identify criminal behaviour.

Actually expecting banks to know their customers at a personal level should be the goal.

I suspect, in contrast, everyone involved likes a fixed 10k limit because it provides a convenient liability hand-off. Compliance can be automated on a much greater level and they can say "we filled out the appropriate forms when required, how were we supposed to know that Hamas Cupcakes Inc was a front?"

2 comments

Agreed on the last bit. Having a clear-cut line where "this must be reported" is I think necessary for liability reasons. There are definitely other transactions that should be reported, in the spirit of the actual AML (anti money laundering) issue. But I think it's necessary to be able to say, in a legal setting, that the required obligation was met and discharged, even if something happened that probably should have been caught.
The government is well-aware of how inflation erodes reporting thresholds. If you look at the obligation to report non-US bank accounts to FinCEN, they've indexed the penalties ($10,000 per line item) to inflation but not the $10,000 aggregate reporting threshold.
So boiling the frog so that eventually all transactions must be reported?