Bank Secrecy Act
Currency Transaction Reporting—Overview
Objective. Assess the bank’s compliance with statutory and regulatory requirements for the reporting of large currency transactions.
A bank must file a Currency Transaction Report (CTR) (FinCEN Form 104) for each transaction in currency76 (deposit, withdrawal, exchange, or other payment or transfer) of more than $10,000 by, through, or to the bank. Certain types of currency transactions need not be reported, such as those involving "exempt persons," a group which can include retail or commercial customers meeting specific criteria for exemption. Refer to the core overview section, "Currency Transaction Reporting Exemptions," pages 90 to 94, for further guidance.
Aggregation of Currency Transactions
Multiple currency transactions totaling more than $10,000 during any one business day are treated as a single transaction if the bank has knowledge that they are by or on behalf of the same person. Transactions throughout the bank should be aggregated when determining multiple transactions. Types of currency transactions subject to reporting requirements individually or by aggregation include, but are not limited to, denomination exchanges, individual retirement accounts (IRA), loan payments, automated teller machine (ATM) transactions, purchases of certificates of deposit, deposits and withdrawals, funds transfers paid for in currency, and monetary instrument purchases. Banks are strongly encouraged to develop systems necessary to aggregate currency transactions throughout the bank. Management should ensure that an adequate system is implemented that will appropriately report currency transactions subject to the BSA requirement.
Filing Time Frames and Record Retention Requirements
A completed CTR must be filed with FinCEN within 15 days after the date of the transaction (25 days if filed electronically). The bank must retain copies of CTRs for five years from the date of the report (31 CFR 103.27(a)(3)).
If a bank has failed to file CTRs on reportable transactions, the bank should begin filing CTRs and should contact the IRS Enterprise Computing Center – Detroit (formerly the Detroit Computing Center)77 to request a determination on whether the backfiling of unreported transactions is necessary.
Additional information about the currency transaction exemption process can be found on FinCEN’s Web site at www.fincen.gov.