7.5 Using CTR to Comply with a Geographical Targeting Order (GTO)

Oracle's CTR application is designed to assist firms with FinCEN Geographical Targeting Orders (GTO). When a GTO is issued, clients should review the criteria of the GTO to understand what regulatory requirements the order is imposing. If applicable, a new threshold set of the CTR scenario can be created to identify which transactions fall within the scope of the order.

Note:

It is possible that a GTO may contain criteria that cannot be identified through the parameters of the scenarios.

GTOs are also dependent on the completeness of the client's customer and transaction data. Since GTOs are in effect for limited periods of time, the newly created GTO threshold set should be enabled only for the duration of the GTO. Given that transactions applicable to GTOs may also need to be investigated and reported via the standard CTR process, GTOs threshold sets should be run in parallel with the client's CTR threshold set. This can result in transactions that show up in a GTO report as well as standard CTR reporting.