Currency transaction report
CTRAlso called cash transaction report, finCEN Form 112
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.
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.
The rules
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 casinosTreats 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 CTRsCommon 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.
