Currency Transaction Report (CTR)

CTR filings should be done when a customer conducts a currency transaction that goes beyond $10,000 or if multiple transactions add up to more than $10,000 within a single day.

The initial version of the CTR required bank tellers to contact law enforcement only if they noticed any suspicious transactions under $10,000. This practice was based on the financial industry’s logic of preserving financial privacy rights. However, with the enactment of the Money Laundering Control Act in 1986, the issue of privacy was no longer a barrier to reporting suspicious activity.

The subsequent version of the CTR introduced a new standard for suspicious transactions, triggering a more thorough investigation for potential money laundering. Currently, the Bank Secrecy Act (BSA) mandates financial institutions to report all currency transactions exceeding $10,000.

Different types of financial institutions have to submit CTRs, including:

• Banks and credit unions
• Casinos and card clubs
• Money services businesses (MSBs)
• Securities brokers and dealers

Recent BSA changes have exempted certain entities from the requirement to report all transactions exceeding $10,000 using a CTR. 

These “exempt persons” include:

• Any bank operating in the United States.
• Government-affiliated organizations, such as state, federal, or local government departments and agencies.
• Businesses whose stocks are publicly traded on major exchanges like Nasdaq or AMEX (except for stocks listed on the Emerging Company Marketplace and those under the Nasdaq Small-Cap Issues heading).

Additionally, financial institutions can exempt certain customers from CTR reporting if they have an existing business relationship and meet specific criteria, like being publicly traded or having a history of consistent large currency transactions.

Companies complete and submit CTRs online through The Financial Crimes Enforcement Network (FinCEN). At a minimum, customer information, including their name, address, SSN, and business name, is required for a CTR. Each report has a specific filing deadline, with CTR deadlines differing from Suspicious Activity Report (SAR) deadlines. 

Typically, the BSA Compliance Officer is responsible for ensuring the timely submission of all CTRs.They must maintain records of submitted CTRs for a designated period and be ready to provide them to authorities upon request.

Banks and financial institutions aren’t obligated to inform customers about CTRs or whether their transactions trigger CTRs unless specifically asked. It’s important to note that this differs from a SAR, which should not be disclosed to the customer.