While the regulation — Part of Title 31 — required financial institutions to file monthly reports concerning these deposits and withdrawals, it was at the discretion of institutions to judge if the activity was unusual for their customer, and to file, or not file, the transaction report accordingly. There is nothing in the statute that set the dollar amount for the large currency reports — that was left to the regulations.
Next up? Toggle navigation. Sign up to receive the latest educational resources about today's financial industry. Verafin respects your privacy. Stay Informed! 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. What amounts do we show in Item 22 for each Part I? If the financial institution does not have 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.
Therefore, if the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, the financial institution would complete a Part I on John Smith. However, if the financial institution does have knowledge the withdrawal was completed on behalf of both John Smith and Jane Smith, the financial institution must complete two Part Is.
Instead, the other boxes in Item 24 should be checked to the extent that they are applicable. Yes, this is acceptable, if the difference was a result of a financial institution following the instructions on rounding dollar amounts.
Banks may implement a policy requiring customers who are deposit accountholders and who want to purchase monetary instruments with currency to first deposit the currency into their deposit accounts while treating this two-step process as one transaction. Nothing within the BSA or its implementing regulations prohibits a bank from instituting such a policy.
If the transactions take place at the branch level, the information regarding the financial institution locations where the transactions took place should be that of the branches involved. The 2B record identifies information regarding the financial institution where transaction s took place.
The number of 2B records is dependent on the number of branches the Parent Financial Institution Information 2A record is reporting on the file. There must be at least one 2B record for each financial institution reporting under the 2A Record. Filers are permitted to associate up to 2B records for a single currency transaction report.
The 2B record precedes all transaction records for the financial institution. Multiple 2B records must be grouped together prior to the associated Transaction Summary 3A Record s. The following are examples of the two batch filing formats involving multiple 2B records that would meet the technical specifications for the FinCEN CTR so the file would be technically acceptable for submission into the BSA E-Filing System as well as permit the data to be loaded properly to reflect the correct associations between the 2B and 3A record s :.
Scenarios CTR two transactions, each in a different branch b-1, b-2 CTR one transaction in a single branch b-3 CTR two transactions, each in a different branch b-1, b-3 CTR one transaction in a single branch b-4 CTR one transaction in a single branch b When the transaction takes place at a branch location, you should include the RSSD number associated with that branch.
If the branch location at which the transaction occurred does not have an RSSD number, however, leave all of Item 40 blank. 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.
This will occur with credit unions. 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. In each instance, the specific identifying information e. For the purposes of currency reporting requirements, a bank includes all of its domestic branch offices 5 31 CFR Deposits made at night or over a weekend or holiday must be treated as if received on the next business day following the deposit.
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. This FinCEN guidance indicates that the currency transactions of separately incorporated businesses should not automatically be aggregated as being on behalf of any one person simply because those businesses are owned by the same person.
It is up to the bank to determine, based on information obtained in the ordinary course of business, whether multiple businesses that share a common owner are, in fact, being operated independently depending on all the facts and circumstances. 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.
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. 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.
Measure content performance. Develop and improve products. List of Partners vendors. A currency transaction report CTR is a bank form used in the United States to help prevent money laundering.
It is part of the banking industry's anti-money laundering AML responsibilities. In order to prevent financial crimes, CTRs require institutions to verify the identity and Social Security Numbers of anyone attempting a large transaction, whether or not that person has an account with the institution. The Bank Secrecy Act initiated the currency transaction report in Recent legislation has identified certain groups known as "exempt persons.
The three categories of "exempt persons" are:. This was primarily due to the financial industry's concern about the right to financial privacy. On October 26, , with the passage of the Money Laundering Control Act, the right to financial privacy ceased being an issue. As part of the Act, Congress stated that a financial institution could not be held liable for releasing suspicious transactional information to law enforcement.
As a result, the next version of the CTR had a suspicious transaction checkbox at the top. CTRs were originally filed on form ; they are now filed on form In addition to a CTR, banks are also required to file Suspicious Activity Reports for transactions that they suspect may involve money from illicit sources.
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