Bank Secrecy Act
Currency Transaction Reporting
Objective. Assess the bank’s compliance with statutory and regulatory requirements for the reporting of large currency transactions.
1. Determine whether the bank’s policies, procedures, and processes adequately address the preparation, filing, and retention of CTRs (FinCEN Form 104).
2. Review correspondence that the bank has received from the IRS Enterprise Computing Center – Detroit (formerly the Detroit Computing Center) relating to incorrect or incomplete CTRs (errors). Determine whether management has taken corrective action, when necessary.
3. Review the currency transaction system (e.g., how the bank identifies transactions applicable for the filing of a CTR). Determine whether the bank aggregates all or some currency transactions within the bank. Determine whether the bank aggregates transactions by taxpayer identification number (TIN), individual taxpayer identification number (ITIN), employer identification number (EIN), or customer information file (CIF) number. Also, evaluate how CTRs are filed on customers with missing TINs or EINs.
4. On the basis of a risk assessment, prior examination reports, and a review of the bank’s audit findings, select a sample of filed CTRs (hard copy or from computer-generated filings) to determine whether:
- CTRs are completed in accordance with FinCEN instructions.
- CTRs are filed for large currency transactions identified by tellers’ cash proof sheets, automated large currency transaction systems, or other types of aggregation systems that cover all relevant areas of the bank, unless an exemption exists for the customer.
- CTRs are filed accurately and completely within 15 calendar days after the date of the transaction (25 days if filed electronically).
- The bank’s independent testing confirms the integrity and accuracy of the MIS used for aggregating currency transactions. If not, the examiner should confirm the integrity and accuracy of the MIS. The examiner’s review should confirm that tellers do not have the capability to override currency aggregation systems.
- Discrepancies exist between the bank’s records of CTRs and the CTRs reflected in the download from the BSA reporting databases.
- The bank retains copies of CTRs for five years from the date of the report (31 CFR 103.27(a)(3)).
5. On the basis of examination procedures completed, including transaction testing, form a conclusion about the ability of policies, procedures, and processes to meet regulatory requirements associated with currency transaction reporting.