Mr. Cullen, for instance, provided an interesting insight on the matter of setting threshold levels that trigger the mandatory reporting system by banks and financial institutions. He said that in truth, there is no absolutely correct level, and that financial authorities in each separate territory must determine the trigger level that would work for it, considering the local context.
In the Philippines, the threshold is set at P500,000 under the Anti-money Laundering Law (Amla) of 2001, meaning, any transaction at this level and above must be reported. In Canada, Mr. Cullen said, the threshold is 10,000 Canadian dollars.
He rued a knee-jerk reaction in certain areas to lower the threshold after a report, attributed supposedly to the World Bank and other global entities, had warned that migrant workers were being used to build up funds for terrorists, and that they had been able to operate below the anti-money laundering radar because they normally send home, each time, only a few hundred dollars at the most.
Yet from Mr. Cullen’s experience, there were many places where he could see hardworking migrant workers sending money to their poor families, but later suspected of being part of a “pooling mechanism” for terrorist funds, just because they happened to be Muslim workers.
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