FinCEN Currency Transaction Report (CTR) FAQ (2023)

As explained in the March 2012 FinCEN guidance (FIN-2012-G002), for critical and non-critical Items, financial institutions must complete those Items for which they have relevant information, regardless of whether or not individual Items are considered critical for technical filing purposes.

For Critical Items, financial institutions must provide the requested information or affirmatively check the "Unknown" (Unknown) box provided in the FinCEN CTR and FinCEN Suspicious Activity Report (SAR) (or any other security report). FinCEN).

For non-critical items, FinCEN expects financial institutions to provide the most complete file information available in each report, consistent with existing regulatory expectations. Based on feedback from law enforcement officials, this information is important for reference purposes. However, the new FinCEN SAR and FinCEN CTR do not create new obligations to collect data, either manually or through an enterprise-wide IT management system, where such collection is not required by current statutes and regulations, especially where such collection would conflict with the financial institution's obligations under any other applicable law. Therefore, a financial institution may leave non-critical fields blank without an asterisk when the information is not readily available.

FinCEN expects financial institutions to have the ability to send information to any of FinCEN's CTR or SAR data fields (or any other FinCEN report). In general, if your financial institution's filing software does not allow the institution to include information in a field without an asterisk where information has been collected and is relevant to the report, the financial institution must complete a discrete file for those transactions until the software is updated If a submission was submitted in which such information was not included due to a limitation in the submission software, an amended submission must be completed using the discrete submission method or an amended batch submission, once it is updated software. These software updates must be implemented within a reasonable period of time.

If your institution has questions about the applicability of this general guidance, contact the FinCEN Regulatory Helpline at (800) 949-2732 for more information.

"General users" of the Bank Secrecy Act (BSA) electronic filing system can only view reports that the "supervising user" has given them permission to view. If you are unable to view or access the new FinCEN CTR, please contact your supervisor user to request access.

Supervisory users of the BSA electronic filing system can view all available FinCEN reports by logging into the BSA electronic filing system. The supervisor user must grant general users access to view new FinCEN reports.

To do this, a supervisor user must first:

1. Log in to the BSA electronic filing system.

2. Select "Manage Users" on the left side under "User Management".

3. Select the general user whose access roles require updating.

4. Select "Reassign Roles".

When accessing the following web page, the supervisor user must:

1. Select the functions ("FinCEN CTR Filer", "FinCEN CTR Batch Filer", "FinCEN SAR Filer", "FinCEN SAR Batch Filer", "FinCEN DOEP Filer", "FinCEN DOEP Batch Filer", etc.) "Remaining Roles" to be added for general user.

2. Move the selected roles to the "Current Roles" box and select "Continue".

After completing all these steps, the general user will now have access to the selected new functions and will be able to access the new FinCEN reports.

Electronic filing instructions can be found atAnnex Cof the document “FinCEN CTR Electronic Filing Requirements”. This document can be found under "Quick Links for Users" on the homepage of the BSA Electronic Filing System (http://bsaefiling.fincen.treas.gov/main.html) or on the "Forms" page of the FinCEN website (http://www.fincen.gov/forms/bsa_forms/).

Furthermore, the instructions are embedded in the discrete presentation version of the FinCEN CTR and are revealed by hovering over the relevant fields with the computer mouse.

Archivers attempting to submit a corrected/amended CTR via the BSA electronic filing system must check "Correct/Modify Previous Report" and enter the previous Document Control Number (DCN)/Identifier (ID) BSA in the appropriate field. The filer must complete the FinCEN CTR in its entirety, including corrected/amended information, save (and print, if desired) a copy of the submission, and submit the submission. The corrected/amended FinCEN CTR will receive a new BSA ID.

To find your DCN/BSA ID for Previous Filing, you will need confirmation received by the General User after successfully submitting the report into the BSA Electronic Filing System. All general users with access to new FinCEN reports automatically receive these confirmations. Contributors may choose to receive these acknowledgments in "ASCII" or "XML" format. Also note that supervisor users cannot view the content of confirmations received by general users.

A BSA submission can be saved at any stage of completion and then later reopened for completion and submission to the BSA's electronic filing system. You must electronically save your submission before it can be submitted to BSA's electronic filing system.NOTE: BSA's electronic filing system is not a record keeping program.When saving a BSA presentation, users must save the presentation to their computer, network or other suitable storage device. For additional information on record keeping requirements under the BSA, see 31 CFR § 1010.430(d) and FAQ #11.

Please note that the BSA electronic filing system will disconnect contributors after a certain period of time if there is no action on the account, even if the contributor is working on the FinCEN CTR. For this reason, FinCEN strongly recommends that taxpayers download the FinCEN CTR template, log out of BSA E-Filing, complete the FinCEN CTR offline, and then log back into BSA E-Filing to upload and submit the report.

A presenter can electronically save the presentation to their computer's hard drive, network drive, or other suitable storage device. Upon clicking the "Save" button, a standard dialog box will appear allowing you to choose the location of your saved report. Once the report is saved, the "Submit" button will be available. A taxpayer may also want to print a paper copy for their financial institution's records.

An archiver must NOT save a copy of the report on a public computer or on a computer that the archiver does not regularly access.This will ensure that the file remains properly protected.

FinCEN regulations have consistently maintained a regulatory requirement that CTRs be submitted within 15 days. Implemented a period of 25 days, referring to the receipt of files on magnetic media (ending in December 2008), to account for the physical transport (dispatch) of magnetic media to the processing center in Detroit, Michigan. FinCEN understands that this business practice has continued with regard to the electronic filing of batches, particularly given the prior public guidance regarding the 25-day period.

In light of the feedback received and acknowledging that some financial institutions may have needed to change their business processes to comply with the rules, FinCEN has determined that it would temporarily maintain the 25-day compliance period referenced in its previous specifications until March 31, 2013. , for those archivers who needed to upgrade their systems to meet established regulatory requirements. This temporary extension of filing requirements was to allow sufficient time for filers to adjust filing schedules to meet established regulatory requirements.

As of April 1, 2013, all FinCEN CTRs must be submitted within 15 calendar days of the reported transaction.

Make sure you complete all of the following steps when completing a single FinCEN CTR:

1. Complete the report in its entirety with all data requested or required to be known by the archiver.

2. Click "Validate" to ensure proper formatting and all mandatory fields filled in.

3. Click "Sign with PIN" - Enter the personal identification number (PIN) that the BSA electronic filing system has assigned to your User ID. If you don't know your PIN, click on the "Manage PIN" link in the left navigation menu to display your PIN.

4. Click "Save" - ​​Taxpayers can also "Print" a paper copy for their records. The "Save" button will allow you to select the location to save your file.

(Video) Completing the FinCEN CTR

5. Click "Submit" - After clicking "Submit", the submission process will start.

After clicking "Send", the sending process starts. Once your submission has been accepted into BSA's electronic filing system, a "Confirmation Page" pop-up window will appear with the following information:

• Tracking ID (a unique tracking ID assigned to the filing by BSA E-Filing)
• Presentation date and time
• Shipping type
• Owner name (sender)
• Owner's email address (sender)
• presentation name

An email will also be sent to the email address associated with your BSA E-Filing account indicating that your submission has been "accepted" for submission in the BSA E-Filing system.

If the confirmation page pop-up does not appear, the BSA electronic filing system did not accept your submission. If you return to the BSA electronic filing login page, your connection has timed out and you must log in to the BSA electronic filing system and resubmit your report. It is recommended that you first close your browser and reopen it before attempting to log into the BSA electronic filing system again.

Once your report is accepted and a confirmation pop-up page appears, the status of your report can be viewed by clicking on the "Follow-up Status" link in the left navigation menu. The status will show as "Accepted".

Within 48 hours, your report will be formally recognized as successfully processed for inclusion in the FinCEN database. The status will change to "Acknowledged" in the "Track Status" view. In addition, a secure message containing the official BSA ID assigned to your report will be sent to your "secure mailbox".

Frequently asked questions associated with FinCEN CTR Part I

Yup. All individual transactions known to a financial institution made by or on behalf of the same person during a single business day shall be aggregated. Debits must be added to debits and credits must be added to credits. If cash debit or credit totals exceed $10,000 on a business day, a CTR is required. If debits and credits exceed $10,000, each can be reported in a single CTR, but financial institutions must not offset debits and credits against each other or reconcile inbound transactions with outbound transactions for cash reporting purposes. Multi-currency transactions must be treated as a single transaction if the financial institution "has knowledge that they are made by or on behalf of any person and result in a deposit or withdrawal of money totaling more than $10,000 during any qualifying day" .

In this regard, institutions should consult the FinCEN ResolutionsFIN-2001-R002yFIN-2012-G001🇧🇷 For example, the requirement to file a CTR can be triggered when an individual deposits more than $10,000 into multiple business accounts. In this case, the submission must be completed with the entities on behalf of which the transactions were carried out and with the person who carried out the transaction (Part I). In a situation where multiple withdrawals involving multiple people have occurred throughout the day, common ownership may be relevant in determining whether aggregation is necessary. If multiple businesses do not operate separately and independently, the institution may conclude that their transactions should be aggregated. A CTR would be completed indicating the entities on whose behalf the transactions were made and the persons who made the transactions. Each entity and individual would be listed in a respective Part I. This reasoning has traditionally been extended to the waiver process as well.

Taxpayers should check "Multiple Transactions" (Item 3) if there are multiple incoming or outgoing transactions of any amount made in a single business day by or for the Part I registrant. "Multiple Transactions" is not the same thing as the “Aggregate transactions” option of Article 24, which involves only multiple transactions, all of which fall below the reporting requirements and require that at least one of the transactions be a cash transaction. The use of Article 24 "Aggregate Transactions" is discussed in more detail in FAQ #27.

For example, if Tom Doe deposited $6,000 into his personal account in the morning and on the same business day deposited an additional $5,000 into his personal account, the submitting institution would verify Item 3 "Multiple Transactions" by completing Part I about Tom Donate . Another example would be if Tom Doe deposits $7,000 into Restaurant ABC's business account, and on the same business day Jane Smith deposits $5,000 into Restaurant ABC's business account, the submitting institution would check Item 3 "Multiple Transactions" upon completion of Part I at the ABC Restaurant; however, the submitting institution would NOT check Item 3 “Multiple Transactions” when completing Part I on Tom Doe or Jane Smith.

There may be instances where, at any given time, a person brings funds to be deposited into multiple accounts at the financial institution. Whether or not to mark “Multiple Transactions” in these cases depends on the procedures of the financial institution. For example, a customer contributes $15,000 and deposits the funds into three different accounts; the financial institution records each transaction individually, opting for policy to define each as a separate transaction. When completing Part I of the driver, the financial institution would verify Item 3 “Multiple Transactions” as a result of its procedures for accounting for transactions individually and treating each as a separate transaction.

FinCEN previously issued guidance in March 2012 that addressed NAICS Code selection in the FinCEN CTR and FinCEN SAR. FinCEN emphasized that financial institutions will continue to be expected to provide only information they have direct knowledge of. As stated in this guide, the issuance of the FinCEN CTR does not create any new obligations or change existing legal and regulatory requirements for the registrar. Also, the use of a NAICS code is not required and a financial institution can still provide a text response about this information in the "Occupation" field. 🇧🇷

Note that batch archivers must useonlythe 3- to 4-digit NAICS codes from our list of approved codes. Discreet contributors can select from the available dropdown built into the CTR.

Please, askFIN-2012-G002for more information.

For technical reporting purposes, Item 20 is a critical field in the FinCEN CTR (identified by *). However, the publication of the FinCEN CTR did not create new obligations or change the existing legal and regulatory expectations of financial institutions when the new report was submitted.

Previous guidance for completing the identification field in an entity's CTR instructed contributors to check the "Other" box and enter "NA" on the line provided. This statement is no longer valid given the addition of the "Unknown" box to Item 20. The addition of the "Unknown" box means that filers will no longer use "NA" or "XX" in certain fields.

Therefore, if the registrar does not have information or knowledge of a “form of identification” of the entity, it must check the “Unknown” box of Item 20.

FinCEN expects, however, financial institutions to provide the most complete reporting information available in each report, regardless of whether or not individual fields are considered critical for technical reporting purposes. Examples of "forms of identification" for an entity might include the entity's business license or documents of incorporation. See 31 CFR § 1010.312 for additional information on identification requirements.

Note that if “Other” is selected in item 20, you must enter the number associated with that other form of identification or fill in the blank in the “Number” box to avoid validation errors.

Road map:Tom Doe deposited $6000 into his personal account. During the same business day, Jane Smith deposited an additional $5,000 into Tom Doe's personal account.

In this scenario, the presenting institution would complete three Parts I, two for Tom Doe and one for Jane Smith. A Part I for Tom Doe would be completed by ticking 2a "Person transacting in own name" and entering $6,000 in Item 21 and personal account number. The other Part I for Tom Doe would be completed by marking 2c "Person in whose name the transaction was made" and entering $5,000 in Item 21 and the account number of your personal account. Part I for Jane Smith would be completed by ticking 2b "Person transacting for another" and entering $5,000 in Item 21 and Tom's personal account number.

How do I correctly complete Part I of the FinCEN CTR for deposits to a joint account? What quantities do we show in Item 21 for each Part I? For example, John and Jane Smith have a joint account. John Smith deposited $5,000 into the account; Later that same business day, Jane Smith deposited $7,000 into the account.

When a deposit is made into a joint account, it is assumed that the deposit was made on behalf of all account holders because all account holders have potential access to the account balance and multiple Parts I are required. For example, the financial institution would complete four Parts I, two for John Smith and two for Jane Smith, as each person has more than one role in Item 2.

One from Part I to John Smith would be completed by marking 2a "Person transacting in his own name" and entering $5,000 in Item 21 and the joint account number. The other Part I for John Smith would be completed by marking 2c "Person in whose name the transaction was made" and entering $7,000 in Item 21 and the joint account number. One from Part I to Jane Smith would be completed by marking 2a "Person transacting in own name" and entering $7,000 in Item 21 and the joint account number. The other Part I for Jane would be completed by marking 2c "Person in whose name the transaction was made" and entering $5,000 in Item 21 and the joint account number.

Note: If Jane Smith did not make a deposit, but John Smith deposited $12,000 into the joint account, there would only be two Part Is. One Part I would go to John Smith as the 2nd "Person Transacting in His Own Name" and put $12,000 into the account joint Item 21 and the affected account number. The other Part I would be for Jane Smith, verifying 2c "Person in whose name the transaction was made", entering $12,000 in Item 21 and providing the affected account number.

24. How do I correctly complete Part I of the FinCEN CTR for withdrawals from a joint account? What quantities do we show in Item 22 for each Part I? For example, John and Jane Smith have a joint account. During one business day, John Smith withdrew $12,000 from the account.

Because John Smith made a withdrawal from the joint account of more than $10,000, the financial institution would include Jane Smith's information only iftemknowledge that the transaction was also being carried out on his behalf. If the financial institution does notnoIf you are aware that the removal was made on behalf of Jane Smith, you are not obligated or prohibited from including Jane Smith in a second Part I.

Therefore, if the financial institution does notnoKnowing that the withdrawal was made in Jane Smith's name, the financial institution would complete a Part I on John Smith. For Item 2 of Part I, the financial institution must tick 2a “Person carrying out transactions on its own behalf” and complete the applicable information for John Smith. Item 22 of Part I on John Smith would be completed by entering $12,000 and providing the affected account number.

However, if the financial institutiondoesis aware that the withdrawal was completed on behalf of John Smith and Jane Smith, the financial institution must complete two Parts I. When completing Part I on John Smith, the financial institution must tick 2a “Person performing transaction in own name” and fill in the applicable information for John Smith. When filling out Part I about Jane Smith, the financial institution would check 2c “Person on whose behalf the transaction was made” and fill in the applicable information for Jane Smith. Item 22 for each Part I would be similarly completed, entering $12,000 and providing the affected account number.

Road map:Bob Smith deposits $6,000 into an account at Hotel ABC. Later that same business day, Lisa Williams deposits $8,000 into an ABC Hotel account.

The financial institution would complete three Parts I for the above scenario:

• A Part I on Bob Smith would be completed by 1) verifying 2b "Person transacting for a third party", 2) completing the applicable information for Bob Smith, and 3) entering $6,000 in Item 21 and providing the affected account number.
• Another Part I for Lisa Williams would be completed by 1) checking 2b "Person transacting for a third party", 2) filling in the applicable information for Lisa Williams, and 3) entering $8,000 in Item 21 and providing the affected account number.
• Another Part I at ABC Hotel would be completed by 1) ticking 2c "Person on whose behalf the transaction was made", 2) ticking Item 3 "Multiple transactions", 3) ticking "If an entity", 4) filling in the corresponding information from ABC Hotel and 5) enter $14,000 in Item 21 and provide the affected account number.

Answer Archivers who are sole proprietors and/or legal entities must follow the instructionsin CTR XML user guide viewhttps://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf.General Instructions Point 17,Individual company reports,and article 18legal entities,inside Page 90.

Frequently asked questions associated with Part I of FinCEN CTR 112

Respondents should check box 24e “Aggregate Transactions” (along with any other applicable boxes under Item 24) only in the following circumstances: 1) the financial institution has not identified any of the persons who made the related transactions, 2) all transactions were below the reporting requirement and 3) at least one of the added transactions was a cash transaction. If the reported aggregated transactions only included deposits made via overnight deposit, the financial institution would not mark "Aggregated Transactions" as none of the aggregated transactions were cash transactions; instead, the financial institution would mark Item 24 as “Overnight Deposit”. A “cash transaction” would include, but not be limited to: the deposit or withdrawal of cash by a person at the teller, a person making a loan payment with cash at the teller, or a person changing money at the teller. 🇧🇷 The “Aggregate Transactions” option is not the same as Item 3 “Multiple Transactions”, which may involve transactions that are above the reporting requirement.

For example, if four deposits of $3,000 were made into the ABC Restaurant business account in one business day and the presenting institution did not identify any of the individual parties to the transaction and at least one of those deposits was made via a cash transaction, the Submitting institution would complete ABC Restaurant Part I by checking Item 3 “Multiple Transactions” and checking “Aggregate Transactions” in Item 24.

However, if the Introducing Institution were to identify the fourth individual transaction, as a result of knowing that the transaction brings ABC Restaurant above the $10,000 threshold, the Introducing Institution would complete Part I on ABC Restaurant by checking Item 3 "Multiple Transactions" and a separate part I in the fourth single transactor. Registrar would NOT mark "Aggregate Transactions" in Item 24 due to having identified one of the transactors.

If four deposits of $3,000 were made to the ABC Restaurant business account via any combination of armored car (FI contract), ATM, mail deposit or delivery, or overnight deposit, i.e., none of the deposits were made through a cashier transaction, the Transactions added box should not be checked. Instead, the other boxes in item 24 should be checked as applicable.

Yes, this is acceptable, if the difference is the result of a financial institution following instructions on rounding dollar amounts. The following scenario describes the two options available for the submitting institution to follow in completing items 21/22 and 25/27:

Road map:A customer deposits $8345.18 into his personal account and also makes a loan payment of $2345.43 on the same business day. The daily report shows that this customer generated $10,690.61 in one business day.

• Option 1: Per the FinCEN CTR instructions, each dollar amount reported in the FinCEN CTR must be rounded to the nearest dollar. Therefore, the financial institution would enter $10,691 in Part I, Item 21 of the FinCEN CTR. In Part II, the financial institution would enter $8,346 in Item 25a and $2,346 in Item 25b. As a result, the Item 25 total would reflect $10,692. The FinCEN CTR will be validated and accepted when the Article 21 total (or Article 22 for a withdrawal transaction) is not greater than the Article 25 total (or Article 27 for a withdrawal transaction). Archivers may internally document as a general note in their FinCEN CTR files that values ​​may differ in these situations as a result of following FinCEN CTR rounding instructions. Both regulators and law enforcement authorities were involved in the FinCEN CTR project and are aware of and accept the potential discrepancy.
• • Option 2: As a way to avoid these differences in the FinCEN CTR, the declarant can round all involved values ​​separately and then sum the separately rounded values. For example, using the scenario above, the filer would round the transactions for $8,345.18 and $2,345.43 separately to $8,346 and $2,346 respectively, which would add up to $10,692, and then enter this value in Part I, Item 21 of the FinCEN CTR. In Part II, the financial institution would enter $8,346 in Item 25a and $2,346 in Item 25b. As a result, item 25's total would reflect $10,692 and items 21 and 25 would match. If applicable, a financial institution is still required to document internally as a general note in its FinCEN CTR files if these amounts differ slightly from the amounts shown in the daily reports due to the rounding of the amounts involved separately.

Banks may implement a policy that requires customers who are deposit account holders and wish to purchase monetary instruments with cash to first deposit currency into their deposit account (treating this two-step process as a single transaction). Nothing within the BSA or its implementing regulations prohibits a bank from instituting such a policy. Therefore, if a customer purchases a currency instrument using $15,000 in the currency that the customer first deposits into the customer's account, at the request of the bank or at the customer's discretion, the financial institution will complete Part I of the FinCEN CTR with the customer's information. training. In Item 25 of Part II, the financial institution would indicate $15,000 as cash income for Item 25d “Purchase of Negotiable Instrument(s)” as shown below. Completing the FinCEN CTR in this manner will notify law enforcement authorities that the currency was used to purchase a negotiable instrument.

Frequently asked questions associated with FinCEN CTR Part III

When submitting the FinCEN CTR for one or more reportable transactions, the submitting institution must complete a Part III for each location where the reportable transactions occurred. FinCEN CTR allows you to enter up to 999 Part III (Financial Institution where transactions are made) in a single submission. If transactions are carried out at the branch level, information on the locations of the financial institutions where the transactions were carried out must be those of the branches involved.

Discreet filing cabinets:To enter additional Part III using the discrete filing version of the FinCEN CTR, the filing institution would select the "+" icon under Part III.

Batch archivers:Batch filers will use the Register of the financial institution where the transactions are carried out (2B) for the same purpose. The 2B record identifies information about the financial institution where the transactions took place. The number of 2B records depends on the number of branches that the parent financial institution (2A) information record reports on file. There must be at least one 2B record for each financial institution that reports under the 2A Record. Reporters can associate up to 999 2B records for a single currency transaction report. The 2B record precedes all financial institution transaction records. Multiple 2B records must be grouped before the associated transaction summary (3A) records.

The following are examples of two batch file formats involving multiple 2B records that would meet the FinCEN CTR technical specifications, making the file technically acceptable for submission to the BSA electronic filing system and allowing the data to be uploaded correctly. to reflect the correct associations between records 2B and 3A:

scenarios
CTR-1: two transactions, each in a different branch (b-1, b-2)
CTR-2: A transaction at a single branch (b-3)
CTR-3: two transactions, each in a different branch (b-1, b-3)
CTR-4: A transaction at a single branch (b-4)
CTR-5: A transaction at a single branch (b-4)

E-File (Version A)
2A (FI)
2B (b-1)
2B (b-2)
3A (CTR-1)
[3B-4C not covered to simplify the example]
9A (resumo b1-2)
2B (b-3)
3A (CTR-2)
[3B-4C not covered to simplify the example]
9A (curriculo b3)
2B (b-1)
2B (b-3)
3A (CTR-3)
[3B-4C not covered to simplify the example]
9A (return to b1,3)
2B (b-4)
3A (CTR-4)
[3B-4C not covered to simplify the example]
3A (CTR-5)
[3B-4C not covered to simplify the example]
9A (resumo b4)
9B (FI Summary)

E-File (Example B)
2A (FI)
2B (b-1)
2B (b-2)
3A (CTR-1)
[3B-4C not covered to simplify the example]
9A (resumo b1-2)
2B (b-3)
3A (CTR-2)
[3B-4C not covered to simplify the example]
9A (curriculo b3)
2B (b-1)
2B (b-3)
3A (CTR-3)
[3B-4C not covered to simplify the example]
9A (return to b1,3)
2B (b-4)
3A (CTR-4)
[3B-4C not covered to simplify the example]
3A (CTR-5)
[3B-4C not covered to simplify the example]
9A (resumo b4)
9B (FI Summary)

A depository institution would select the Research, Statistics, Supervision and Discount (RSSD) number. You can find your institution's RSSD number athttp://www.ffiec.gov/nicpubweb/nicweb/nichome.aspxohttp://www.ffiec.gov/find/callreportsub.htm.

When the transaction is carried out at a branch, you must include the RSSD number associated with that branch. However, if the branch where the transaction was made does not have an RSSD number, leave the entire Item 40 blank. This can occur if an RSSD number has not yet been issued for a new branch, but we expect that few deposit takers do not have an RSSD for each branch. If the branch has the same RSSD number as the financial institution as a whole, you must use the general RSSD number for the financial institution. This will happen with savings and credit cooperatives.

Please note that it is important that the information contained in the submission about the agency or other location where the transaction took place is as complete and accurate as possible. This greatly helps law enforcement understand where the transactions took place.

Yes, the sending institution's contact phone number must be the contact office phone number listed in item 55.

Additional questions or comments regarding these FAQs should be directed to FinCEN's regulatory helpline at 800-949-2732. Financial institutions wishing to report suspicious transactions that may be related to terrorist activity should call the Financial Institutions Hotline toll free at (866) 556-3974 (7 days a week, 24 hours a day). The purpose of the hotline is to expedite the delivery of this information to law enforcement authorities. Financial institutions must immediately report any imminent threat to law enforcement in the local area.