The Production of Suspicion in Retail Banking: An Examination of Unusual Transaction Reporting
This chapter examines the process of Unusual Transaction Reporting (UTR) using a case study of retail banking. UTRs are the first step in the reporting chain undertaken by Canadian banks, and the generation of UTRs is a key step in the detection of anti-money laundering and counter-terrorist financing step. It demonstrates that although banks may invest significantly in training employees to identify risky transactions based on institutional best practices and legal obligations, idiosyncratic notions of suspicion can enter the reporting process when employees generate UTRs. An examination of this process, comparing the best practices of the bank with the subjective and often moralizing judgements of bank employees, demonstrates that a gap exists in some cases between what financial institutions and Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act may conceive of as suspicious, and what employees examining individual transactions may believe is suspicious. It then closes with a discussion of the problems that may arise from this disjuncture of policy and practice.