Currency transaction report

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Currency transaction report

CTRAlso called cash transaction report, finCEN Form 112

Definition

A currency transaction report is a filing that US financial institutions send to FinCEN for any cash transaction of more than $10,000 in a business day. It covers deposits, withdrawals, exchanges and other cash payments. A CTR is a routine threshold report, filed whether or not the activity looks suspicious.

CASH IN OR OUTAGGREGATE DAYOVER $10,000FILE CTR
Fig. 1 · Currency transaction report
31 CFR 1010.311 · 31 CFR 1010.313
Key rules31 CFR 1010.311 · 31 CFR 1010.313
Applies toBanks, money services businesses, broker-dealers and other financial institutions other than casinos
RegionsUS
01

How it works

When a customer deposits, withdraws or exchanges more than $10,000 in physical currency, the institution records who conducted the transaction and on whose behalf, verifies their identity and files FinCEN Form 112 through the BSA E-Filing System. Multiple cash transactions by or for the same person in one business day are added together, so two deposits of $6,000 at different branches still trigger a report. The filing is due within 15 days.

Banks can exempt certain customers, such as listed companies and other banks, from CTR filing under FinCEN's exemption rules. CTRs feed law enforcement databases and help investigators trace cash. Customers who split cash into smaller amounts to stay under the threshold commit structuring, a federal offence, and the pattern itself is grounds for a suspicious activity report even when no CTR is required.

Step 1Capture cash activityRecord every cash deposit, withdrawal and exchange by customer.
Step 2AggregateAdd up cash by or for the same person in one business day.
Step 3Identify partiesVerify who conducted the transaction and on whose behalf.
Step 4File Form 112Submit the CTR to FinCEN within 15 days.
Step 5Watch for structuringReview patterns just below $10,000 for a possible SAR.
02

The rules

US · 1 March 2011 in its current Chapter X form; the duty dates from the Bank Secrecy Act 197031 CFR 1010.311Filing obligations for reports of transactions in currency, 31 CFR 1010.311, with filing time in 31 CFR 1010.306(a)(1)

Requires a report of each deposit, withdrawal, exchange or other cash payment or transfer of more than $10,000, filed within 15 days of the transaction.

Banks, money services businesses, broker-dealers and other financial institutions other than casinos
US · 1 March 2011 in its current Chapter X form31 CFR 1010.313Aggregation of currency transactions, 31 CFR 1010.313

Treats multiple cash transactions by or on behalf of the same person in one business day as a single transaction when the institution knows of them.

Financial institutions filing CTRs
03

Common questions

Is a CTR the same as a SAR?

No. A CTR is filed automatically for cash over $10,000, with no judgement about suspicion. A SAR is filed when a firm suspects money laundering or other crime, at any amount. One transaction can lead to both.

Does the customer get told about a CTR?

CTRs are routine and are not confidential in the way SARs are, so staff can explain the requirement. Staff must not help a customer avoid a report by splitting the cash.

Do UK or EU banks file CTRs?

The UK has no general cash threshold report. Some EU member states require reports on large cash transactions under national law, and the EU anti-money laundering package caps cash payments for goods and services.