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The Bank Secrecy Act of 1970 requires financial institutions to file a Currency Transaction Report for any transaction that involves more than $10,000 in currency. Transactions may include deposits, withdrawals, currency exchanges, and wire transfers. The transaction must involve U.S. paper money or coins; the CTR does not apply to transactions financed by checks, money orders, or other instruments.
Determine if the customer qualifies for an exemption. Cash transactions by banks, government entities, publicly traded companies and any subsidiaries are exempted from CTR requirements. Banks may also file a Designation of Exempt Person form for most commercial banking customers that maintain a regular account and conduct a business that would reasonably involve large currency transactions.
Determine if the transaction is reportable. If the customer is not exempt and the transaction involves more than $10,000 in currency, it must be reported. If the bank has knowledge of multiple transactions for one customer in one business day that exceed this limit, they should be considered a single transaction and reported.
Obtain the Currency Transaction Report, Form 104, from the Financial Crimes Enforcement Network website at fincen.gov.
Complete the requested information. Part I of the CTR identifies the person conducting the transaction. Part II of the CTR details the type of transactions and the amounts involved. Part III outlines information about the reporting financial institution.
File the completed Form 104. Most financial institutions should file online at bsaefiling.fincen.treas.gov. The form may also be filed by mailing to:
Enterprise Computing Center Attn: CTR P.O. Box 33604 Detroit, MI, 48232
In addition to banks, financial institutions also include casinos, pawn shops, check cashers, issuers and sellers of money orders and travelers checks, and currency exchangers.
The completed CTR must be filed within 15 days of the reportable transaction, if filed manually, or within 25 days of the reportable transaction, if filed electronically. The financial institution must retain a copy of the completed form for five years from the reporting date. Failure to file a CTR is punishable by civil and criminal penalties.
I am a corporate finance professional, with over ten years of experience in all facets of business management. I also have extensive experience with personal investment strategies, analysis, and planning. I have served as a bank examiner with the Federal Reserve, as a personal trust officer, and more recently as a corporate controller and senior financial analyst. I hold a BA in accounting and economics as well as an MBA in finance.