A customer came in with $20,000 cash. [3B-4C not addressed to simplify example] What are the expectations for completing the Items with an asterisk ("critical") and without an asterisk ("non-critical") found on the FinCEN CTR or any other FinCEN report? Under the BSA regulations, the definition of person found at31 CFR 1010.100(mm)is an individual, a corporation, a partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture, or other unincorporated organization or group, an Indian Tribe (as that term is defined in the Indian Gaming Regulatory Act), and all entities recognizable as legal personalities. Since an entity cannot physically conduct a transaction, the only selection that would apply is 2c Person on whose behalf transaction was conducted. In addition, if filing on an entity, a filer must select the checkbox (Item 4b) for If entity in Part I. Complete the report in its entirety with all requested or required data known to the filer. The 2B record precedes all transaction records for the financial institution. [3B-4C not addressed to simplify example] After all these steps are completed, the general user will now have access to the selected new roles and can access the new FinCEN reports. If the financial institution doesnothave knowledge that the withdrawal was conducted on behalf of Jane Smith, then it would neither be required to nor prohibited from listing Jane Smith in a second Part I. If the Confirmation Page pop-up is not displayed, your filing was not accepted for submission by the BSA E-Filing System. What is an IRS Currency Transaction Report? In order to detect potential fraud and irregularities in the banking system, banks are required to electronically file Currency Transaction Reports (CTRs) for transactions that exceed $10,000. Please note that if Other is selected in Item 20, you must either put in the number associated with that other form of identification or space fill the Number box to avoid a validation error. 34. When a deposit is made into a joint account, the deposit is presumed to be made on the behalf of all account holders because all account holders have potential access to the account balance, and multiple Part Is are required. The addition of the Unknown box means that filers will no longer use NA or XX in certain fields. Understanding Currency Transaction Reports (CTRs), How Currency Transaction Reports Currently Work. Based upon feedback from law enforcement officials, such information is important for query purposes. Structuring transactions occurs when a person, acting alone or in conjunction with, or on behalf of, other persons, conducts or attempts to conduct one or more transactions in currency, in any amount, at one or more financial institutions, on one or more days, in any manner, for the purpose of evading the CTR requirements.12 31 CFR 1010.100(xx). 3A (CTR-1) Multipletransactions must be treated as a single transaction if thefinancial institution has knowledge that (1) they are by oron behalf of the same person, and (2) they result in eithercurrency received (Cash In) or currency disbursed (CashOut) by the financial institution totaling more than $10,000during any one business day. This is distinct from a Suspicious Activity Report, which should not be disclosed to the customer. Adam received his master's in economics from The New School for Social Research and his Ph.D. from the University of Wisconsin-Madison in sociology. As noted in that guidance, the issuance of the FinCEN CTR does not create any new obligation or otherwise change existing statutory and regulatory requirements for the filing institution. If the previous DCN/BSA ID is not known, filers should enter all zeros (14 in total) for the previous DCN/BSA ID. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check Aggregated transactions as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 Night Deposit. A teller transaction would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. TransUnion does offer an estimate. The updates largely depend on when creditors report account activity, and whether they report it to each of the three credit bureaus. Banks and credit unions must report currency transactions exceeding $10,000, whether they involve deposits, withdrawals, or the exchange of currency. For non-critical Items, FinCEN expects financial institutions will provide the most complete filing information available within each report consistent with existing regulatory expectations. Refer to Appendix G: Structuring for additional information. Capital One Fined Millions for Ineffective Money-Laundering Protections, US Crime Agency Proposes Rules for Self-Hosted Crypto Wallets, Countries Where Bitcoin Is Legal and Illegal, Cryptocurrency Regulations Around the World. Please note that it is important to have the information within the filing regarding the branch or other location at which the transaction took place as complete and accurate as possible. How do I complete the FinCEN CTR for purchases of monetary instruments with currency? You can find out more about our use, change your default settings, and withdraw your consent at any time with effect for the future by visiting Cookies Settings, which can also be found in the footer of the site. Where can I find the instructions for completing the new FinCEN CTR? If criminal activity is suspected relating to a transaction (or series of transactions), a credit union may want to determine whether or not to file a Suspicious Activity Report (SAR). 3A (CTR-2) 3A (CTR-4) 2. Forms to be used in making reports of currency transactions may be obtained from BSA E-Filing System (31 CFR 1010.306(e)). (deposit, withdrawal, exchange of currency, or other payment or transfer) of more than $10,000 by, through, or to the bank.2 31 CFR 1010.311. If the bank becomes aware, either through self-identification or through an examination, that it has failed to file CTRs on reportable transactions, or filed CTRs with errors, the bank must begin complying with CTR requirements. Item 56 asks for the filing institutions contact phone number. See 31 CFR 1010.306(a)(2), 31 CFR 1010.330(e)(3), 31 CFR 1010.340(d), 31 CFR 1020.320(d), 31 CFR 1021.320(d), 31 CFR 1022.320(c), 31 CFR 1023.320(d), 31 CFR 1024.320(c), 31 CFR 1025.320(d), 31 CFR 1026.320(d), 31 CFR 1029.320(d), and 31 CFR 1022.380(b)(1)(iii). Once FinCEN provides a backfiling or amendment determination, the bank should follow the instructions for backfiling or amending CTRs on FinCENs website.24 See Instructions for Backfiling or Amending Currency Transaction Reports on FinCENs website. However, if the filing institution identified the fourth individual transactor, as a result of knowing the transaction takes ABC Restaurant over the $10,000 threshold, then the filing institution would complete a Part I on ABC Restaurant checking Item 3 Multiple transactions and a separate Part I on the fourth individual transactor. bank must electronically file a Currency Transaction Report (CTR) for each transaction in currency (deposit, withdrawal, exchange of currency, or other payment or transfer) of more than $10,000 by, through, or to the bank.1 However, banks may exempt certain types of customers from currency transaction reporting.2 Pursuant to the Money Launderi. Developing Conclusions and Finalizing the Exam, Risks Associated with Money Laundering and Terrorist Financing, Treatment of Armored Car Service Transactions Conducted on Behalf of Financial Institution Customers or Third Parties for Currency Transaction Report Purposes, Currency Transaction Report Aggregation for Businesses with Common Ownership, Customer Due Diligence Requirements for Financial Institutions: Final Rules, FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements, Filing FinCENs new Currency Transaction Report and Suspicious Activity Report, Frequently Asked Questions Regarding the FinCEN Currency Transaction Report, FinCEN CTR (Form 112) Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a Doing Business As (DBA) Name, Currency Transaction Reporting: Aggregation, Instructions for Backfiling or Amending Currency Transaction Reports, Beneficial Ownership Requirements for Legal Entity Customers, Purchase and Sale of Certain Monetary Instruments Recordkeeping, Foreign Correspondent Account Recordkeeping, Reporting and Due Diligence, Private Banking Due Diligence Program (Non-U.S. Consistent with this FinCEN guidance, if the bank determines that the businesses are independent, then the common ownership does not require aggregation of the separate transactions of these businesses. Effective October 3, 2019, the following frequently asked questions (FAQs) have been provided to assist financial institutions in their use of the FinCEN CTR. In completing a Part I on John Smith, the financial institution would check 2a Person conducting transaction on own behalf and complete the applicable information for John Smith. Option 2: As a means of avoiding these differences on the FinCEN CTR, the filer can round up all the amounts involved separately and then aggregate the separately rounded amounts. A Currency Transaction Report, or CTR, is a mandatory report which must be filed for currency transactions that exceed $10,000, as part of the bank's anti-money laundering requirements. In this example, the financial institution would complete four Part Is, two for John Smith and two for Jane Smith since each person has more than one Item 2 role. If there were four $3,000 deposits made into ABC Restaurants business account via any combination of Armored car (FI Contract), ATM, Mail Deposit or Shipment, or Night Deposit, i.e., without any of the deposits being made via a teller transaction, the Aggregated transactions box should not be checked. Online Out of Area Apps and Adverse Action. 4. If cash debit or credit totals exceed $10,000 in a business day, a CTR is required. Both regulators and law enforcement were involved in the designing of the FinCEN CTR, and are aware and accepting of the possible discrepancy. 4. Verification of identity in any other case must be made through a document, other than a bank signature card, that is normally acceptable as a means of identification when cashing checks for nondepositors (e.g.,a drivers license or credit card). This compensation may impact how and where listings appear. Are Currency Transaction Reports Confidential? Specifically, examiners should determine whether these internal controls are designed to mitigate and manage ML/TF and other illicit financial activity risks and comply with CTR requirements. 77 Fed. For critical Items, financial institutions must either provide the requested information or affirmatively check the Unknown (Unk.) Any suspicious or unusual activity should be reported by a financial institution in the manner prescribed by its appropriate federal regulator or BSA examiner. Batch filers:Batch filers will utilize the Financial Institution Where Transaction(s) Take Place (2B) Record for this same purpose. A Part I on Bob Smith would be completed by 1) checking 2b Person conducting transaction for another, 2) completing the applicable information for Bob Smith, and 3) entering $6,000 in Item 21 and providing the account number affected. This usually happens once a month, or at least every 45 days. In addition, a secure message containing the official BSA ID assigned to your report will be sent to your Secure Mailbox., FAQs associated with Part I of the FinCEN CTR. A completed CTR must be electronically filed with FinCEN within 15 calendar days after the date of the transaction.20 31 CFR 1010.306(a)(1). The corrected/amended FinCEN CTR will be assigned a new BSA ID that will be sent to the filer in the FinCEN CTR acknowledgement. Specifically, this section covers: A bank must electronically file a Currency Transaction Report (CTR) for each transaction in currency1 31 CFR 1010.100(m) defines currency as coin and paper money of the United States or any other country that is designated as legal tender and that circulates and is customarily used and accepted as a medium of exchange in the country of issuance. 22. This is known as structuring. FinCEN regulations have consistently maintained a regulatory requirement that CTRs be filed within 15 days. CTR-4: one transaction in a single branch (b-4) Ans. 5. 9A (b4 summary) The filing institution would NOT check Aggregated transactions in Item 24 due to the fact that it identified one of the transactors. CTR-2: one transaction in a single branch (b-3) Department of the Treasury FinCEN Certain agricultural operations will periodically deal in cash volumes that big but as we will discuss, attempting to avoid a CTR being filed can result in . He is a CFA charterholder as well as holding FINRA Series 7, 55 & 63 licenses. Reg. A structured transaction is a series of smaller transactions, which are broken up to avoid the $10,000 reporting requirements for the Bank Secrecy Act (BSA). One Part I for Tom Doe would be completed by checking 2a "Person conducting transaction on own behalf" and entering $6,000 into Item 21 and the account number of his personal account. Yes, the filing institutions contact phone number should be the phone number of the contact office noted in Item 55. When saving a BSA filing, users must save the filing to their computer, network, or other appropriate storage device. Scenario: Tom Doe deposited $6,000 into his personal account. 2B (b-1) A currency transaction report (CTR) is a form used by the US financial institutions to help prevent instances of money laundering. Investopedia does not include all offers available in the marketplace. Structuring is illegal under federal law, with strict penalties for both the customer and the bank employee. Financial institutions should immediately report any imminent threat to local-area law enforcement officials. CTR-5: one transaction in a single branch (b-4), E-File (Variant A) How do we record reportable transactions that occurred at multiple branches? A smurf is a colloquial term for a money launderer who seeks to evade scrutiny from government agencies by breaking up large transactions. In Part II, the financial institution would enter $8,346 in Item 25a and $2,346 in Item 25b. The Save button will allow you to select the location to save your filing. Recent legislation has identified certain groups known as "exempt persons.". Until FinCEN directs otherwise, if euros are involved and the country of origin is unknown, enter BE for Belgium in Item 26/28, as applicable. After clicking Submit, the submission process begins. [3B-4C not addressed to simplify example] Banks do not have to tell customers about CTRs unless the customer asks. 2. How do I properly complete Part I on the FinCEN CTR for withdrawals from a joint account? The option Aggregated transactions is not the same as Item 3 Multiple transactions, which can involve transactions that are above the reporting requirement. Beginning June 1, 2018, financial institutions are required to file the updated Currency Transaction Report (FinCEN CTR) which adheres to the changes defined in Federal Register notice posted on February 20, 2016.1 Thethree categories of "exempt persons"are: When the CTR was initiallyimplemented, the judgment of a bank teller was the only thing that would lead to asuspicious transaction of less than $10,000 being reported to law enforcement. 1 Check all box(es) that apply: Section A--Person(s) on Whose Behalf Transaction(s) Is Conducted 5 Doing business as (DBA) 2 Individual's last name or entity's name 3 First name 4 Middle initial 6 SSN or EIN 7 Address (number, street, and apt. Filers are permitted to associate up to 999 2B records for a single currency transaction report. Effective July 1, 2012, FinCEN mandated electronic filing of certain BSA reports, including the CTR. How do I properly complete Part I on the FinCEN CTR for deposits into a joint account? 12. Reg. If your institution has questions regarding the applicability of this general guidance, please contact the FinCEN Regulatory Helpline at (800) 949-2732 for further information. 24. By clicking on the Save button a standard dialog box will appear to allow you to choose the location for your saved report. If applicable, a financial institution should still internally document as a general note to its FinCEN CTR files if these amounts differ slightly from the amounts shown on the daily reports due to rounding the amounts involved separately. When a bank suspects that a person is structuring transactions to evade CTR filing, it must file a SAR.14 31 CFR 1020.320(a)(2)(ii). A bank signature card may be relied upon only if it was issued after documents establishing the identity of the individual were examined and notation of the specific information was made on the signature card. 2. Click Sign with PIN Enter the personal identification number (PIN) the BSA E-Filing System has assigned to your user ID. When completing Part I on the conductor, the financial institution would check Item 3 Multiple transactions as a result of its procedures to post the transactions individually and treat each one as a separate transaction. A Currency Transaction Report (CTR) should be filed when a transaction or series of transactions exceeds the $10,000 threshold within a 24 hour period. Generally, any person in a trade or business who receives more than $10,000 in cash in a single transaction or in related transactions must file a Form 8300. Another example would be if Tom Doe deposited $7,000 into ABC Restaurants business account and then later in the same business day Jane Smith deposited $5,000 into ABC Restaurants business account, the filing institution would check Item 3 Multiple transactions when completing a Part I on ABC Restaurant; however, the filing institution would NOT check Item 3 Multiple transactions when completing a Part I on Tom Doe or Jane Smith. A filer should NOT save a copy of the report on a public computer or a computer that is not regularly accessed by the filer.This will ensure that the file remains appropriately secured. FinCEN understands that this business practice had continued with respect to batch e-filing, particularly considering previous public guidance referencing the 25-day period. Non-real estate loan applicants can use our online form to request a loan. When should I save the copy of the FinCEN CTR that is being filed using the BSA E-Filing System? If you frequently make transactions over $10,000, then you should become familiar with the Currency Transaction Report and how it could affect your taxes. Therefore, if a customer purchases a monetary instrument using $15,000 in currency that the customer first deposits into the customers account, whether at the requirement of the bank or at the customers discretion, the financial institution would complete Part I of the FinCEN CTR with the customers information. 3A (CTR-4) Electronic filing instructions can be found inAttachment Cof the FinCEN CTR Electronic Filing Requirements document. You can learn more about the standards we follow in producing accurate, unbiased content in our. To comply with regulatory requirements, management must ensure that systems or practices appropriately aggregate currency transactions throughout the bank and report currency transactions subject to the BSA requirement to file CTRs. SAR Thresholds 2B (b-4) Consistent with this FinCEN guidance, once the bank determines that the businesses are not independent of each other or of their common owner, then the transactions of these businesses should be aggregated going forward.9 Id. For example, if a credit union has reason to believe a person is structuring transactions, a SAR is required. Reg. In addition to reviewing correspondence from FinCENs BSA E-Filing System, examiners may review other information, such as recent independent testing or audit reports, to aid in their assessment of the banks reporting of currency transactions. The Clayton Antitrust Act is designed to promote business competition and prevent the formation of monopolies and other unethical business practices. The following scenario outlines the two choices available for the filing institution to follow in completing Items 21/22 and Items 25/27: Scenario:A customer deposits $8,345.18 into his or her personal account and also makes a loan payment of $2,345.43 in the same business day. Cookies collect information about your preferences and your devices and are used to make the site work as you expect it to, to understand how you interact with the site, and to show advertisements that are targeted to your interests. A bank must verify and record the name and address of the individual presenting a transaction, as well as record the identity, account number, and Social Security or taxpayer identification number, if any, of any person or entity on whose behalf such a transaction is conducted. This may occur if an RSSD number has not yet been issued for a new branch, but we expect few depository institutions to not have an RSSD for each branch. A filer may also want to print a paper copy for your financial institutions records. However, the release of the FinCEN CTR did not create any new obligations or otherwise change existing statutory and regulatory expectations of financial institutions in filing the new report. For these items, FinCEN filing instructions state that the bank must either provide the requested information or check unknown.17 FinCEN (April 2020), FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements. FinCEN expects that banks will provide the most complete filing information available, consistent with existing regulatory expectations, regardless of whether the individual fields are deemed critical for technical filing purposes.18 FinCEN (March 29, 2012), FIN-2012-G002 Filing FinCENs new Currency Transaction Report and Suspicious Activity Report. If the bank receives correspondence from FinCEN identifying data quality errors, it should follow any required actions that FinCEN outlines in the correspondence. When recording the occupation, profession, or type of business of the individual or entity listed in Part I, use specific descriptions such as doctor, carpenter, attorney, used car dealership, plumber, truck driver, hardware store, etc. For example, the requirement to file a CTR may be triggered by an individual depositing more than $10,000 into multiple business accounts. Filers should check Multiple transactions (Item 3) if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I. You can download or print current or past-year PDFs of Form FinCEN104 directly from TaxFormFinder. [3B-4C not addressed to simplify example] Examples of forms of identification for an entity could include the entitys business license or incorporation documents. Additionally, instructions are embedded within the discrete filing version of the FinCEN CTR and are revealed when scrolling over the relevant fields with your computer mouse.. 2B (b-1) Types of currency transactions subject to reporting requirements individually or by aggregation include, but are not limited to: deposits and withdrawals, automated teller machine (ATM) transactions, denomination exchanges, loan payments, currency transactions used to fund individual retirement accounts (IRAs), purchases of certificates of deposit, funds transfers paid for in currency, monetary instrument purchases, certain transactions involving armored car services,7 For additional information on CTR filing requirements for transactions conducted through armored car services, refer to FinCEN (July 12, 2013), FIN-2013-R001 Treatment of Armored Car Service Transactions Conducted on Behalf of Financial Institution Customers or Third Parties for Currency Transaction Report Purposes. and currency to or from prepaid access. For example, a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing as a matter of policy to define each as a separate transaction. For example, employees who complete CTRs generally should not also be responsible for the decision to file the reports. Currency Transaction Report (CTR), must be filed by casinos to report each transaction in currency involving cash-in and cash-out of more than $10,000 in a gaming day (31 CFR 1021.311). 13. The previous guidance for completing the identification field on the CTR for an entity instructed filers to check the Other box and enter NA on the line provided. In this scenario, the filing institution would complete three Part Is, two for Tom Doe and one for Jane Smith. Can we obtain a copy of a FinCEN CTR that we filed using the BSA E-Filing System? The offers that appear in this table are from partnerships from which Investopedia receives compensation. You can find your institutions RSSD number athttp://www.ffiec.gov/nicpubweb/nicweb/nichome.aspxorhttp://www.ffiec.gov/find/callreportsub.htm. For example, if there were four $3,000 deposits made into ABC Restaurants business account in one business day, and the filing institution did not identify any of the individual transactors, and at least one of these deposits was made via a teller transaction, the filing institution would complete a Part I on ABC Restaurant checking Item 3 Multiple transactions and checking Aggregated transactions in Item 24. 2B (b-1) See also 12 CFR 208.62, 211.5(k), 211.24(f) and 225.4(f) (Federal Reserve); 12CFR 353.3 (FDIC); 12 CFR 748.1(c) (NCUA); 12 CFR 21.21 and 12 CFR 163.180 (OCC). If you do not know your PIN, please click on the Manage PIN link in the left navigation menu for your PIN to be displayed. A filer can electronically save the filing to his/her computer hard drive, a network drive, or other appropriate storage device. However, if the bank determines that these businesses (or one or more of the businesses and the private accounts of the owner) are not operating separately or independently of one another or their common owner (e.g., the businesses are staffed by the same employees and are located at the same address, the bank accounts of one business are repeatedly used to pay the expenses of another business, or the business bank accounts are repeatedly used to pay the personal expenses of the owner), the bank may determine that aggregating the businesses transactions is appropriate because the transactions were made on behalf of a single person. What are the steps for properly submitting a single (discrete) FinCEN CTR filing through the BSA E-Filing System? A Suspicious Activity Report (SAR) must be filed when financial institutions become aware of suspicious behavior that could potentially be crime-related. The corrected/amended FinCEN CTR will be assigned a new BSA ID. Instead, the other boxes in Item 24 should be checked to the extent that they are applicable. Banks, government agencies, or public corporations are exempt from needing CTRs when they transact large amounts. Transactions such as these can lead to a bank filing a "Suspicious Activity Report" (SAR) (31 C.F.R. 9. What is the proper way to complete the FinCEN CTR for sole proprietorships and legal entities operating under multiple DBAs? We last updated the Currency Transaction Report in February 2023, so this is the latest version of Form FinCEN104, fully updated for tax year 2022. Since John Smith made a withdrawal from the joint account in excess of $10,000, then the financial institution would list Jane Smiths information only if ithasknowledge that the transaction was also being conducted on her behalf. The Part I for Jane Smith would be completed by checking 2b "Person conducting transaction for another" and entering $5,000 into Item 21 and the account number of Toms personal account. 3A (CTR-5) When Should a Currency Transaction Report Be Filed? 14. Is it acceptable to indicate terms such as "homemaker, "retired, or "unemployed" as descriptions for occupations? - He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. Filers can internally document as a general note to their FinCEN CTR files that the amounts may differ in these situations as a result of following the FinCEN CTR rounding instructions. CTRs act as a paper trail for cash transactions, and are filled out by bank personnel for each deposit, withdrawal, currency exchange or other payment or transfer greater than $10,000 in . In Part II Item 25, the financial institution would indicate $15,000 as cash in for Item 25d Purchase of negotiable instrument(s) as shown below. Casinos and card clubs must file CTRs for cash transactions over $10,000 related to gaming activities, such as the purchase of chips or the redemption of winnings. Filers that are sole proprietorships and/or legal entities should follow the instructions in the CTR XML User Guide See https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf. 3. What Is a Smurf and How Does Smurfing Work? It is recommended that you first close out of your browser and then re-open it before attempting to log into the BSA E-Filing System again. 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