Reporting Thresholds, With the Numbers in One Table

Threshold rules are the part of this subject most often misdescribed, and the part where quoting a number from memory does the most damage.

What a threshold does

It triggers an obligation at a value. Above it, something must be done: enhanced due diligence, a report, or additional record keeping.

The obligation falls on the institution. The customer experiences it as a request.

The categories of threshold

Transaction value, above which enhanced checks apply. Reporting values, above which a report is filed. Aggregation rules, under which linked transactions are added together. And occasional-transaction values for customers without an ongoing relationship.

Four categories, each with its own figure, each set in the implementing rules.

Why I am not quoting figures

Because they change, because they differ between the general framework and the AIFC regime, and because a wrong number here causes real harm. The current instrument is the only reliable source.

A summary that states a figure is a summary that will be wrong at some point without anyone noticing.

What customers should understand instead

That thresholds exist, that linked transactions are aggregated, and that structuring transactions to stay below them is itself a recognised offence in most frameworks.

That last point is the one worth remembering. Splitting a payment to avoid a threshold is more visible than the original payment would have been.

The aggregation rule

Transactions that appear linked by timing, counterparty or purpose are treated as one for threshold purposes. This exists specifically to defeat structuring.

What happens above a threshold

More documentation, and in some cases a report filed with an authority. A report is not an accusation and is not communicated to the customer.

What a customer should do

Transact at the size the commercial purpose requires, document it, and answer requests completely.

Platforms that collect the documents the regulator expects ask at the threshold rather than after it. Venues that report what they are required to report are also the ones least likely to freeze a balance while deciding what to do, and Collect & Exchange states its documentation requirements by tier.