As of October 3, 2019, the following Frequently Asked Questions (FAQs) have been provided to assist financial institutions in using the FinCEN CTR.
1. What are the expectations for completing the asterisked ("critical") and unstarred ("not critical") items found in the FinCEN CTR or any other FinCEN report?
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.
2. How do I fulfill my underlying obligation to submit a complete and accurate report if my archiving software does not allow me to include known information in a field without an asterisk?
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.
3. When I login to BSA E-Filing, I don't see the new FinCEN CTR.
"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.
4. Where can I find instructions for completing the new FinCEN CTR?
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.
5. What should I enter under "Display Name"?
The display name can be any name the financial institution chooses to use to identify the specific submission (for example, Bank CTR 4-4-2012). The file naming process is decided by the financial institution and can help the financial institution keep track of its BSA files. We recommend using a naming convention that is easy to understand and track for audit/review and record keeping purposes.
6. How do I file a corrected/changed FinCEN CTR through the BSA electronic filing system?
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.
7. How do I correct/modify a previous CTR submission through the BSA electronic filing system if I don't have the previous DCN/BSA ID?
If the previous DCN/BSA ID is not known, taxpayers must enter all "zeros" (total of 14) for the previous DCN/BSA ID. This information was published in aWarningon October 31, 2011. This notice applies to corrections/amendments to any prior submission. 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 be given a new BSA ID which will be sent to the archiver upon acknowledgment of the FinCEN CTR. The new BSA ID will start with the number "31".
8. Can we obtain a copy of a FinCEN CTR that we file through the BSA's electronic filing system?
BSA's electronic filing system is not a record keeping program; consequently, archivers cannot access or view previously archived reports. The BSA's electronic filing system provides tracking information on previous report submissions and confirmations of reports accepted by the BSA. BSA Electronic Filing System UsersYou must saveand you can print a copy of the FinCEN CTR before submitting it. FinCEN does not provide copies of submitted reports to archivers.
9. When should I save the copy of the FinCEN CTR being filed through BSA's electronic filing system?
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.
10. Where can I save a report that is being filed electronically?
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.
11. What are my record keeping requirements when I submit a file electronically?
After submitting a report through the BSA electronic filing system, filers must retain a hard copy or electronic copy of the report in accordance with applicable record retention policies and procedures. Taxpayers are reminded that they generally must keep copies of their records for five years. 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).
12. What is the deadline for submitting the FinCEN CTR? I saw reference to 15 and 25 days.
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.
13. What are the steps to successfully submit a single (discreet) FinCEN CTR submission through the BSA electronic filing system?
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.
14. How can I validate that my Discrete Filing submission has been correctly accepted by the BSA electronic filing system?
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
15. I am submitting the FinCEN CTR about an entity; however, all selections in 2a-2c refer to one person. Which selection would you choose when completing an entity claim?
In accordance with BSA regulations, the definition of “person” found in31 CFR 1010.100 (mm)is “an individual, corporation, partnership, trust or estate, corporation, association, union, joint venture or other unincorporated organization or group, Indian tribe (as that term is defined in the Indian Gaming Act) and all entities recognized as legal entities." Since an entity cannot physically perform a transaction, the only selection that applies is 2c "Person on whose behalf the transaction was performed". Also, if archiving an entity, the archiver must check the box checkbox (Item 4b) to "If an entity" in Part I.
16. What happens if more than one "role" (item 2) applies to the person listed in Part I?
If more than one Item 2 option applies to a Part I person, a separate Part I section on that person will be prepared for each Item 2 option. For example, if the Part I person made a deposit of $5,000 in your personal account and a separate deposit of $7,000 in the account of another person/entity, there will be a Part I on that person who reports option 2a in the personal deposit with that amount and account number in Item 21 “Amount in cash". There will be a second Part I on that person, informing option 2b about the movement of the account of the person/entity with that value and account number in Item 21.Taxpayers will proceed to create a Part I for all other persons involved in the transactions, which in this example will be the person/entity on whose behalf the $7,000 transaction was performed, reporting option 2c, with the $7,000 in which are involved. and the Article 21 account number.
17. Should we add "multiple transactions"? What is the correct way to populate a CTR for transactions involving multiple business entities?
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.
18. When do you check the "Multiple transactions" box (Item 3)?
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.
19. How do I determine whether or not to list a North American Industry Classification System (NAICS) Code?
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.
20. Is it acceptable to use terms such as "housewife", "retired" or "unemployed" as descriptions of occupations?
When recording the occupation, profession or type of business of the person or entity listed in Part I, use specific descriptions such as "doctor", "carpenter", "lawyer", "used car salesman", "plumber", "truck driver". " “. ”, “unemployed”, “homemaker” or “retired” should be used, add current or former occupation if you know (e.g. “construction contractor for self-employed”, “retired teacher” or “unemployed carpenter” ) Financial institutions should pay special attention to retail customers who continually make large cash deposits.
21. Is a “form of identification” (Item 20) required for an entity? If so, what information would we enter in that field?
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.
22. What amount is included in item 21/22 when the Part I person was a driver and transacted on your behalf?
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.
23. How do I correctly complete Part I of the FinCEN CTR for deposits into 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 in...
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 a weekday, John…
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.
25. What is the correct way to complete Part I of the FinCEN CTR when different people deposit into the same merchant account?
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.
26. What is the correct way to complete the FinCEN CTR for sole proprietorships and legal entities operating under multiple DBAs?
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
27. When do you check the "Added Transactions" box (item 24)?
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.
28. When we round off values in the FinCEN CTR, the total for item 25/27 may differ from item 21/22 due to rounding. Is this acceptable?
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.
29. We are introducing the FinCEN CTR for reportable transactions involving euros; however, we are not sure of the country of origin. Which country did we select in item 26/28?
Until FinCEN indicates otherwise, if Euros and country of origin are unknown, insert "BE" for Belgium in Article 26/28, as applicable.
30.How do I complete the FinCEN CTR for purchases of currency-based monetary instruments?
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
31. How do we record reportable transactions that occurred across multiple branches?
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:
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)
[3B-4C not covered to simplify the example]
9A (resumo b1-2)
[3B-4C not covered to simplify the example]
9A (curriculo b3)
[3B-4C not covered to simplify the example]
9A (return to b1,3)
[3B-4C not covered to simplify the example]
[3B-4C not covered to simplify the example]
9A (resumo b4)
9B (FI Summary)
E-File (Example B)
[3B-4C not covered to simplify the example]
9A (resumo b1-2)
[3B-4C not covered to simplify the example]
9A (curriculo b3)
[3B-4C not covered to simplify the example]
9A (return to b1,3)
[3B-4C not covered to simplify the example]
[3B-4C not covered to simplify the example]
9A (resumo b4)
9B (FI Summary)
32. I represent a depositary institution and would like to know the type of identification of my financial institution in Item 40 of the CTR. Do I include information at the agency or financial institution level?
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.
33. Article 55 now calls for a contact office and not a contact person. What information must be provided in this field?
The sending institution must provide the name of the office that should be contacted for additional information about the report. It is the choice of the archival institution as to which office it should be. Examples might include the "Compliance Office", the "Security Office", the "BSA Office" or the "Risk Management Office". The office may or may not be located at the location identified in the same Part III.
34. Item 56 requests the contact telephone number of the presenting institution. Should this be the number associated with the contact office listed in item 55?
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.
Do you file a CTR for currency exchange? ›
A bank must electronically file a Currency Transaction Report (CTR) for each transaction in currency1 (deposit, withdrawal, exchange of currency, or other payment or transfer) of more than $10,000 by, through, or to the bank.
Federal law requires financial institutions to report currency (cash or coin) transactions over $10,000 conducted by, or on behalf of, one person, as well as multiple currency transactions that aggregate to be over $10,000 in a single day. These transactions are reported on Currency Transaction Reports (CTRs).What information is required on a currency transaction report? ›
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.How are multiple currency transactions treated for CTR reporting? ›
Multiple currency transactions resulting in either cash in or cash out totaling more than $10,000 during any one business day must be treated as a single transaction, if the bank has knowledge that they are conducted by or on behalf of any person.Who is exempt from filing a CTR? ›
Under Phase 1, transactions conducted by banks, government departments or agencies, and listed public companies and their subsidiaries are exempt from CTR reporting. Under Phase 2, transactions in currency by businesses that meet specific requirements are exempt from CTR reporting.What amount of money triggers a suspicious activity report? ›
Dollar Amount Thresholds – Banks are required to file a SAR in the following circumstances: insider abuse involving any amount; transactions aggregating $5,000 or more where a suspect can be identified; transactions aggregating $25,000 or more regardless of potential suspects; and transactions aggregating $5,000 or ...Which transactions are reported CTR? ›
As per the PMLA rules, Bank is required to submit the details of, All cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency.What are the three exemptions from CTR reporting? ›
- Auctioning of goods.
- Chartering or operating ships, buses, or aircraft.
- Engaging in gaming of any kind, such as selling lottery tickets.
- Engaging in investment advisory or investment banking services.
- Engaging in union activities.
- Operating a pawn brokerage.
The requirement that financial institutions verify and record the identity of each cash purchaser of money orders and bank, cashier's, and traveler's checks in excess of $3,000.How quickly must a CTR be filed? ›
FinCEN regulations have consistently maintained a regulatory requirement that CTRs be filed within 15 days.
What is the penalty for not filing a CTR? ›
For example, incomplete or inaccurate CTRs can bring fines of $500 each. Your credit union could face fines of $10,000 if a required CTR is not filed within 15 days of the transaction, with further fines of $10,000 for each day a required report is not filed.What is the difference between a CTR and a SAR? ›
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. A Suspicious Activity Report (SAR) must be filed when financial institutions become aware of suspicious behavior that could potentially be crime-related.Will a CTR trigger an audit? ›
Although having a CTR on your IRS file may cause you to be audited, structuring your transactions to avoid the CTR is illegal, and it will cause you even more headaches.How do you avoid CTR? ›
Structuring. One way people might try to get around a CTR is by breaking up payments into amounts of less than $10,000. For example, someone might deposit $6,000 in the bank on Monday and, on Friday, put in $5,000 to avoid triggering a CTR for a deposit totaling $11,000.Is a CTR same as 8300? ›
The Financial Crimes Enforcement Network (FinCEN) oversees and enforces the Bank Secrecy Act, and so a CTR is filed using the IRS/FinCEN Form 8300. When there are multiple transactions done within one business day that add up to $10,000 a CTR must be filed.Does cashing a check trigger a CTR? ›
Since the CTR filing obligation is only triggered by transactions of more than $10,000 in currency (defined in the FFIEC BSA/AML Exam Manual as coin and paper money of the United States or any other country as long as it is customarily accepted as money in the country of issue), the threshold is not met by deposits of ...Can a sole proprietor be CTR exempt? ›
A sole proprietorship may be treated as an exempt person if it meets the definition of a non-listed business or a payroll customer. When designating a sole proprietorship as an exempt person, a bank must take those reasonable and prudent steps to assure itself that the sole proprietorship is a bona fide business.What size bank transactions are reported? ›
Note that under a separate reporting requirement, banks and other financial institutions report cash purchases of cashier's checks, treasurer's checks and/or bank checks, bank drafts, traveler's checks and money orders with a face value of more than $10,000 by filing currency transaction reports.What amount of money is flagged? ›
Depositing a big amount of cash that is $10,000 or more means your bank or credit union will report it to the federal government. The $10,000 threshold was created as part of the Bank Secrecy Act, passed by Congress in 1970, and adjusted with the Patriot Act in 2002.What is the circumstance s that you have to make a suspicious transaction report? ›
The law requires you to make a report if you suspect that any property represents the proceeds of serious crime, was used in connection with serious crime, or is intended to be used in serious crime.
What amount of money gets flagged when deposited? ›
The IRS requires banks and businesses to file Form 8300, the Currency Transaction Report, if they receive cash payments over $10,000. Depositing more than $10,000 will not result in immediate questioning from authorities, however. The report is done simply to help prevent fraud and money laundering.What is a good CTR? ›
The CTR Equation
Basically, it's the percentage of people who click your ad (clicks) divided by the ones who view your ad (impressions). As far as what constitutes a good click through rate, the average is around 1.91% for search and 0.35% for display.
A high CTR is a good indication that users find your ads and listings helpful and relevant. CTR also contributes to your keyword's expected CTR, which is a component of Ad Rank. Note that a good CTR is relative to what you're advertising and on which networks.What is considered multiple transactions on a CTR? ›
Aggregated Transactions. whenever there are multiple cash-in or cash-out transactions of any amount conducted in a single business day by, or for, a person.What is the threshold limit for CTR for any single individual transaction? ›
Currency Transaction Report or CTR means report on cash transaction exceeding such amount as may be specified by the National Executive Committee by notification in the official Gazette. Threshold for reporting currency transaction report is Rupees two million or above.What is the bank $10000 rule? ›
The Internal Revenue Code (IRC) provides that any person who, in the course of its trade or business, receives in excess of $10,000 in cash in a single transaction (or in two or more related transactions) must report the transaction to the IRS and furnish a statement to the payer.What if I have more than 250000 in the bank? ›
Any individual or entity that has more than $250,000 in deposits at an FDIC-insured bank should see to it that all monies are federally insured. It's not only diligent savers and high-net-worth individuals who might need extra FDIC coverage.What is the $10000 rule? ›
Federal law requires a person to report cash transactions of more than $10,000 by filing IRS Form 8300PDF, Report of Cash Payments Over $10,000 Received in a Trade or Business.Do wire transfers trigger CTR? ›
However, it's important to know that wire transfers, both domestic and international, are subject to bank scrutiny. Banks must report all wire transfers over $10,000 using a Currency Transaction Report (CTR) and submit it to the Financial Crimes Enforcement Network (FinCEN).What is the purpose of filing a CTR? ›
A currency transaction report (CTR) is a report that U.S. financial institutions are required to file with FinCEN for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency of more than $10,000.
When should a CTR and STR be submitted? ›
It is further clarified that cash transaction reporting by branches to their Principal Officer should invariably be submitted on monthly basis (not on fortnightly basis) and the Principal Officer, in turn, should ensure to submit CTR for every month to FIU-IND within the prescribed time schedule.How do banks identify suspicious activity? ›
The algorithms look for anomalous behavior — e.g. a large volume of cash transactions; large transfers to a country where the customer does not do business.) At this point, a compliance staffer investigates the alert and decides whether the activity is “suspicious” or not.What amount triggers an audit? ›
The IRS will be notified if you make a large deposit over the $10,000 amount. You should be prepared to show how and why you received that money if you file a tax return.Do check cashing places report to the IRS? ›
Check cashers are not subject to the requirement to report suspicious activity, for example, a business that is involved exclusively in check cashing has no requirement to file a SAR.How much cash can you deposit over a year? ›
When it comes to cash deposits being reported to the IRS, $10,000 is the magic number. Whenever you deposit cash payments from a customer totaling $10,000, the bank will report them to the IRS. This can be in the form of a single transaction or multiple related payments over the year that add up to $10,000.How much money can you deposit in a bank without getting reported? ›
How Much Money Can You Deposit Before It Is Reported? Banks and financial institutions must report any cash deposit exceeding $10,000 to the IRS, and they must do it within 15 days of receipt.What is the difference between a Form 8300 and a CTR? ›
Form 8300 can be filed electronically with the Bank Secrecy Act or it can be filed by mailing in a hard copy to the Internal Revenue Service. Individuals and businesses alike must file a CTR when they receive one cash transaction that is $10,000 or more or related cash transactions that aggregate to $10,000 or more.Should I be worried about a CTR report? ›
Although having a CTR on your IRS file may cause you to be audited, structuring your transactions to avoid the CTR is illegal, and it will cause you even more headaches.What is an example of a suspicious transaction? ›
Buying and selling of a security with no discernible purpose or in circumstances which appear unusual. The intensity of transactions for an inactive trading account suddenly increases without plausible reason. The entry of matching buys and sells in particular securities, creating an illusion of trading.Should I worry about form 8300? ›
Is a Form 8300 required? Yes. Once the dealership receives cash exceeding $10,000, a Form 8300 must be filed. The deal not going through may in fact be an attempt to launder illegal funds.
Does Form 8300 trigger an audit? ›
The most common mistake is for the business or trade to forget to submit a written statement along with IRS Form 8300, which generally triggers an audit. As a result, we suggest meeting with a tax professional before you file IRS Form 8300.