 CBK Circular No 1 of 2016 reminded banks of the requirements under POCAMLA on large cash transactions e.g. to determine the legitimacy of funds. The Circular was informed by:  Findings from target inspections had revealed that corruption proceeds had been transacted through large cash transactions.  Failure by institutions to obtain information to determine legitimacy of customer transactions.
 Comply with international best practice on large cash transactions.  Comparative studies on how other jurisdictions treat large cash transaction. What is the impact of Circular No.1 of 2016? The circular is part of measures to enhance the effectiveness of monitoring cash transactions. As explained, monitoring each cash transaction is an essential pillar of an effective AML/CFT framework.