Overview
Currency Transaction Reports (CTRs) are mandatory filings under the Bank Secrecy Act (BSA) that financial institutions must submit to the Financial Crimes Enforcement Network (FinCEN) for currency transactions exceeding $10,000. For trading platforms, money transmitters, and cryptocurrency exchanges, CTR compliance is a foundational requirement of anti-money laundering (AML) programs.
Failure to file CTRs is a serious violation that can result in civil penalties up to $100,000 per violation, criminal prosecution, and potential revocation of your money services business (MSB) license. This guide provides comprehensive instructions for understanding CTR requirements, identifying reportable transactions, and implementing compliant filing procedures.
⚠ Federal Crime
Willful failure to file CTRs is a federal crime under 31 U.S.C. 5322, punishable by up to 5 years in prison and fines up to $250,000 for individuals ($500,000 for organizations). "Structuring" transactions to avoid CTR filing is itself a separate federal crime.
CTR Filing Requirements
Every financial institution must file a CTR when it conducts or facilitates a currency transaction exceeding $10,000. This applies to transactions by, through, or to the institution.
Who Must File CTRs?
The following financial institutions are required to file CTRs:
- Banks and credit unions
- Money services businesses (MSBs) - including money transmitters, check cashers, and currency exchangers
- Securities broker-dealers
- Casinos
- Cryptocurrency exchanges - classified as MSBs by FinCEN
- Futures commission merchants and introducing brokers in commodities
💡 Trading Platform Application
If your trading platform is registered as an MSB with FinCEN (including crypto exchanges, peer-to-peer platforms, or any platform that transmits money), you must file CTRs for all qualifying currency transactions. This includes both cash deposits/withdrawals and certain digital currency conversions to/from fiat.
What Is "Currency"?
For CTR purposes, "currency" means:
- Coin and paper money of the United States or any other country
- Cashier's checks, bank drafts, traveler's checks, or money orders with a face value of $10,000 or less received in designated reporting transactions
⚠ Cryptocurrency and CTRs
Currently, cryptocurrency itself is NOT considered "currency" for CTR purposes. However, when a customer exchanges cryptocurrency for U.S. dollars or other fiat currency exceeding $10,000, the fiat portion may trigger CTR requirements depending on the structure of the transaction. Consult updated FinCEN guidance as this area is evolving.
$10,000 Threshold and Aggregation Rules
The CTR threshold is $10,000 in a single transaction or in multiple transactions aggregated over a single business day.
Single Transaction Test
A CTR is required if a single transaction involves more than $10,000 in currency:
Example 1: Single Transaction
Scenario: Customer deposits $15,000 cash into their trading account at 2:00 PM on Monday.
Result: CTR required. Single transaction exceeds $10,000.
Filing Deadline: 15 calendar days from the transaction date.
Multiple Transaction Aggregation
Financial institutions must aggregate all currency transactions by or on behalf of the same person during a single business day. If the total exceeds $10,000, a CTR is required.
Example 2: Multiple Transactions - Same Day Aggregation
Scenario: Customer makes the following transactions on Tuesday:
- 9:00 AM - Deposits $4,000 cash
- 1:00 PM - Deposits $3,500 cash
- 4:30 PM - Deposits $3,200 cash
Total: $10,700
Result: CTR required. Multiple transactions by same person aggregate to over $10,000 in one business day.
Knowledge Standard for Aggregation
You must aggregate transactions when you have knowledge that they are by or on behalf of the same person. Knowledge includes:
- Actual knowledge - You definitively know the transactions are related
- Should have known - Facts would lead a reasonable person to conclude transactions are related
- Willful blindness - Deliberately avoiding knowledge to circumvent CTR requirements
⚠ "Should Have Known" Standard
Courts have held that financial institutions cannot turn a blind eye to obvious patterns. If multiple transactions bear indicia of being conducted by or for the same person (same IP address, linked accounts, family members, etc.), you may be required to aggregate them even without explicit confirmation.
CTR Threshold Decision Tree
Do You Need to File a CTR?
CTR Filing Timeline
CTRs must be filed within 15 calendar days after the date of the transaction. This is a strict deadline.
Filing Deadline Calculator
⚠ No Extensions
Unlike Suspicious Activity Reports (SARs), there is no extension mechanism for CTR filing deadlines. Late filings are violations and may result in civil money penalties.
Business Day vs. Calendar Day
| Concept | Definition | Application |
|---|---|---|
| Business Day (for aggregation) | Day the institution is open for substantially all business functions | Aggregate all transactions within a single business day |
| Calendar Day (for filing deadline) | Every day including weekends and holidays | 15 calendar days from transaction to file CTR |
FinCEN CTR Form Instructions
CTRs are filed electronically through the BSA E-Filing System using FinCEN Form 112 (Currency Transaction Report).
Required Information
The CTR form requires detailed information about the transaction and the parties involved:
CTR Form Sections
- Part I: Information about the person(s) on whose behalf the transaction is conducted
- Part II: Individual(s) conducting the transaction (if different from Part I)
- Part III: Details of the currency transaction amount, type, and account numbers
- Part IV: Financial institution filing the report
Part I: Person(s) Involved in Transaction
For each person on whose behalf the transaction is conducted, collect:
- Name - Full legal name (first, middle, last for individuals; legal entity name for businesses)
- Taxpayer Identification Number (TIN) - SSN for individuals, EIN for businesses
- Address - Permanent street address (not P.O. Box)
- Date of Birth - For individuals
- Identification Document - Type and number (driver's license, passport, etc.)
- Occupation or Type of Business
💡 Multiple Persons
If the transaction is conducted by or on behalf of more than one person, you must complete a separate section for each person. For example, if two joint account holders each deposit $6,000 cash on the same day (totaling $12,000), include both on the CTR.
Part III: Transaction Information
Document the details of the currency transaction:
- Date of transaction
- Total amount - In U.S. dollars
- Type of transaction - Deposit, withdrawal, exchange, etc.
- Foreign currency involved - If applicable, specify currency and exchange rate
- Account number(s) affected
| Transaction Type Code | Description | Examples |
|---|---|---|
| 1 | Deposit(s) | Cash deposits into customer accounts |
| 2 | Withdrawal(s) | Cash withdrawals from customer accounts |
| 3 | Exchange of currency | USD to EUR, crypto-to-fiat conversions |
| 4 | Cash payments | Payments of currency for services |
| 5 | Currency received | Receipt of currency not deposited |
| 99 | Other | Transactions not fitting above categories |
Multiple Transactions Aggregation
Proper aggregation is critical for CTR compliance. Financial institutions must have systems and procedures to identify when multiple transactions should be aggregated.
Aggregation Scenarios
Scenario A: Multiple Deposits - Same Person, Same Day
Facts:
- Customer John Smith deposits $5,000 at 10 AM
- John Smith deposits $6,000 at 3 PM
- Same business day
Analysis: Aggregate both transactions. Total = $11,000.
Action: File CTR for $11,000 in deposits by John Smith.
Scenario B: Transactions at Multiple Branches
Facts:
- Customer Jane Doe deposits $7,000 at Branch A at 9 AM
- Customer Jane Doe deposits $4,500 at Branch B at 2 PM
- Same business day, same financial institution
Analysis: Even though transactions occur at different locations, same institution must aggregate. Total = $11,500.
Action: File CTR for $11,500 in deposits by Jane Doe.
Scenario C: Related Parties
Facts:
- ABC Corp deposits $6,000 cash
- John Smith (CEO of ABC Corp) deposits $5,000 cash into his personal account
- Same business day
Analysis: If you have knowledge that John Smith is acting on behalf of ABC Corp or both transactions are related, you must aggregate. Total = $11,000.
Action: File CTR noting relationship between parties.
Technical Implementation
To comply with aggregation requirements, financial institutions typically implement:
- Real-time transaction monitoring systems that flag currency transactions
- Name-matching algorithms to identify transactions by the same individual or entity
- Daily aggregation reports generated at end of business day
- Manual review processes for edge cases and related party analysis
Exemptions from CTR Filing
Certain categories of customers may be exempt from CTR reporting. However, exemptions must be formally designated and filed with FinCEN—they do not apply automatically.
Exempt Customer Categories
| Exemption Category | Description | Requirements |
|---|---|---|
| Banks and Credit Unions | Domestic banks, credit unions, and federal branches | Automatic exemption; no filing required |
| Government Entities | Federal, state, local government agencies | File FinCEN Form 110 to designate exemption |
| Listed Public Companies | Companies whose stock is traded on national exchange | File Form 110; must verify listing status |
| Subsidiaries of Listed Companies | Wholly-owned domestic subsidiaries of listed companies | File Form 110; verify ownership structure |
| Non-Listed Businesses | Qualifying non-public companies meeting eligibility criteria | File Form 110; annual review required |
| Payroll Customers | Customers withdrawing currency for payroll purposes | File Form 110; document payroll purpose |
⚠ Exemption Does Not Mean No Monitoring
Even if a customer is exempt from CTR filing, you must still monitor their transactions for suspicious activity. Exemptions apply only to CTRs—not to Suspicious Activity Reports (SARs). An exempt customer's unusual transactions may still require a SAR.
Non-Listed Business Exemption Criteria
A non-publicly traded business may qualify for exemption if it:
- Maintains a transaction account at your institution for at least 2 months
- Frequently engages in currency transactions exceeding $10,000
- Is incorporated or organized under U.S. law or operates in the U.S.
- Is not engaged in illegal activities or raising red flags for suspicious activity
Filing and Maintaining Exemptions
To designate an exempt customer:
- Verify eligibility - Ensure customer meets exemption criteria
- File FinCEN Form 110 - Designation of Exempt Person
- File within 30 days - Initial exemption must be filed within 30 days of designation
- Biennial review - Review exemption status every two years and re-file Form 110
- Monitor continuously - If customer's status changes (e.g., delisting from exchange), revoke exemption
Structuring vs. Legitimate Activity
"Structuring" refers to conducting financial transactions in a specific pattern to avoid triggering CTR requirements. Structuring is a federal crime under 31 U.S.C. 5324, even if the underlying funds are legitimate.
What Is Structuring?
Structuring occurs when a person:
- Conducts or attempts to conduct one or more transactions in currency
- In amounts at or below $10,000
- For the purpose of evading CTR filing requirements
Example: Classic Structuring
Scenario: Customer needs to deposit $25,000 in cash proceeds from selling a car. To avoid paperwork, the customer makes the following deposits over three days:
- Monday: $8,000
- Tuesday: $8,500
- Wednesday: $8,500
Analysis: This is structuring. The customer deliberately broke up a single transaction into smaller amounts to stay under the $10,000 CTR threshold.
Consequence: Federal crime. Financial institution must file a Suspicious Activity Report (SAR) in addition to any CTRs that may apply.
Red Flags of Structuring
Structuring Red Flags
- Multiple deposits or withdrawals just under $10,000 threshold
- Customer makes transactions at multiple branches on the same day, each below $10,000
- Customer declines to complete a transaction after learning it will trigger a CTR
- Customer asks about CTR thresholds or reporting requirements before conducting transaction
- Pattern of transactions at $9,000, $9,500, or other amounts just below $10,000
- Customer uses multiple accounts or multiple people to conduct related transactions
- Transactions increase in frequency as they approach but don't exceed $10,000
- Customer appears nervous or reluctant to provide identification when approaching threshold
Legitimate Business Patterns
Not all patterns of transactions below $10,000 are structuring. Legitimate business operations may naturally result in recurring transactions below the threshold:
Example: Legitimate Business Pattern
Scenario: A restaurant deposits daily cash receipts Monday through Friday:
- Monday: $3,200
- Tuesday: $2,800
- Wednesday: $3,500
- Thursday: $4,100
- Friday: $8,900
Analysis: This pattern reflects the restaurant's actual daily receipts. There is no intent to evade CTR requirements—amounts vary naturally with business volume.
Conclusion: NOT structuring. However, financial institution should document the business rationale and monitor for changes in pattern.
Responding to Suspected Structuring
If you suspect structuring activity:
- Do not tip off the customer - Do not refuse the transaction or tell the customer you suspect structuring
- Complete the transaction - Process the transaction as requested
- File a SAR - Submit a Suspicious Activity Report within 30 days
- File CTRs if applicable - If any single transaction or daily aggregate exceeds $10,000, file the required CTR
- Document your analysis - Maintain internal records explaining why you suspect structuring
⚠ Never Tip Off
Telling a customer that their transaction will be reported, or that you suspect structuring, is itself a violation of federal law (31 U.S.C. 5318(g)(2)). This is called "tipping off" and can result in civil and criminal penalties.
Electronic CTR Filing (BSA E-Filing)
All CTRs must be filed electronically through FinCEN's BSA E-Filing System. Paper CTR filings are no longer accepted.
BSA E-Filing System Setup
E-Filing System Access Steps
- Register your institution at https://bsaefiling.fincen.treas.gov/
- Obtain a BSA E-Filing account (requires institutional information)
- Designate E-Filing contacts and supervisors
- Download BSA E-Filing software or use web-based portal
- Test filing capabilities with sample CTR
- Establish internal workflow for CTR preparation and approval
- Set up automated reminders for 15-day filing deadline
Filing Methods
| Method | Best For | Requirements |
|---|---|---|
| Batch Filing | High-volume institutions filing many CTRs | XML file upload; requires technical integration |
| Web Form | Low-volume filers or occasional CTRs | Manual data entry through web browser |
| BSA E-Filing Software | Mid-volume filers | Desktop application; download from FinCEN |
Filing Confirmation and Recordkeeping
After submitting a CTR electronically:
- Acknowledgment - BSA E-Filing system provides immediate acknowledgment of submission
- BSA Identifier - Each filed CTR receives a unique BSA Identifier for tracking
- Acceptance Status - Check status to confirm acceptance (typically within 1-2 business days)
- Rejection Notices - If rejected for errors, correct and re-file immediately
💡 System Maintenance
BSA E-Filing System undergoes periodic maintenance (typically Sunday mornings). Plan CTR filing to avoid last-minute submissions on deadline day that might coincide with system downtime.
CTR Recordkeeping Requirements
Financial institutions must maintain copies of all filed CTRs and supporting documentation for five years from the date of filing.
Required Records
- Filed CTRs - Complete copy of each CTR submitted to FinCEN
- Supporting documentation - Transaction records, account statements, identification documents
- Aggregation analysis - Documentation showing how multiple transactions were identified and aggregated
- Exemption files - For exempt customers, Form 110 filings and biennial reviews
- Filing confirmations - BSA Identifiers and acceptance notices from FinCEN
Organized Recordkeeping System
Best practices for CTR recordkeeping:
- Centralized filing system - Maintain all CTRs in a searchable database or document management system
- Index by customer name and date - Enable quick retrieval for examinations or law enforcement requests
- Link to source transactions - Connect CTR to underlying account activity and transaction records
- Separate from customer files - CTRs should be maintained in compliance files, not customer service files
- Secure access - Limit access to compliance personnel and authorized staff
⚠ Examiners Will Check
During BSA/AML examinations, regulators routinely test CTR compliance by sampling large currency transactions and verifying that CTRs were filed. Inability to produce CTR records or demonstrate aggregation processes is a serious deficiency.
Retention Schedule
| Record Type | Retention Period | Trigger Date |
|---|---|---|
| Filed CTRs | 5 years | From date of filing |
| CTR supporting documentation | 5 years | From date of transaction |
| Exemption designations (Form 110) | 5 years | From date exemption terminated |
| Aggregation work papers | 5 years | From date of analysis |
Penalties for CTR Violations
CTR violations carry severe civil and criminal penalties under the Bank Secrecy Act and related statutes.
Civil Money Penalties
| Violation Type | Civil Penalty | Authority |
|---|---|---|
| Negligent failure to file CTR | Up to $500 per violation | 31 U.S.C. 5321(a)(6)(A) |
| Pattern of negligent violations | Up to $50,000 per violation | 31 U.S.C. 5321(a)(6)(B) |
| Willful failure to file CTR | Greater of $100,000 or 50% of transaction amount | 31 U.S.C. 5321(a)(5)(C) |
| Structuring or causing structuring | Civil forfeiture of structured amounts | 31 U.S.C. 5317(c) |
Criminal Penalties
- Willful failure to file CTR: Up to 5 years imprisonment and $250,000 fine (individuals) / $500,000 (organizations)
- Structuring: Up to 5 years imprisonment and $250,000 fine (individuals) / $500,000 (organizations)
- Structuring connected to other crimes: Up to 10 years imprisonment
- Failure to maintain CTR records: Up to 5 years imprisonment and fines
⚠ Willfulness Standard
A violation is "willful" if it involves a knowing or reckless disregard of BSA requirements. You don't need to know the specific statute—it's sufficient that you knew of the reporting requirement and deliberately failed to comply or were reckless in your compliance efforts.
Recent Enforcement Examples
Case Study: Cryptocurrency Exchange
Facts: A cryptocurrency exchange registered as an MSB failed to file CTRs for customer fiat withdrawals exceeding $10,000. Over 18 months, the exchange processed approximately $4.2 million in reportable currency transactions without filing a single CTR.
Penalty: $500,000 civil money penalty, plus required retention of independent compliance monitor for 3 years.
Lesson: Crypto platforms must implement the same CTR controls as traditional financial institutions.
Case Study: Money Transmitter - Structuring
Facts: A money transmitter's compliance officer instructed tellers to break up large transactions into multiple transactions under $10,000 to reduce CTR filing burden.
Penalty: Criminal prosecution of compliance officer; 3 years imprisonment. Company assessed $2 million civil penalty and required to implement enhanced compliance program.
Lesson: Deliberate structuring by financial institution employees is a serious crime.
Implementing a CTR Compliance Program
Effective CTR compliance requires policies, procedures, technology, and training.
Written Policies and Procedures
Your BSA/AML compliance program must include written procedures for:
- Identifying reportable transactions - Thresholds, currency definitions, transaction types
- Aggregating multiple transactions - Same-day aggregation, knowledge standards
- Collecting customer information - Required data elements for CTR filing
- Filing CTRs timely - Workflow from transaction date to 15-day deadline
- Designating exemptions - Eligibility criteria, filing Form 110, biennial reviews
- Identifying structuring - Red flags, escalation procedures, SAR filing
- Recordkeeping - 5-year retention, organized filing system
Technology Solutions
Many financial institutions use automated transaction monitoring systems to support CTR compliance:
- Real-time alerts - Flag transactions at or approaching $10,000
- Daily aggregation reports - Identify customers with multiple transactions totaling over $10,000
- Name-matching algorithms - Link transactions by the same customer across accounts and channels
- Auto-population of CTR forms - Pull customer and transaction data into CTR templates
- Deadline tracking - Calendar management to ensure 15-day filing deadline
- Exemption management - Track designated exempt customers and biennial review dates
Staff Training
All employees who handle currency transactions must receive CTR training:
CTR Training Topics
- Definition of "currency" and reportable transactions
- $10,000 threshold and aggregation requirements
- How to identify and escalate potential structuring
- Customer information collection requirements
- Prohibition on "tipping off" customers
- Consequences of CTR violations (civil and criminal penalties)
- Role of each employee in CTR compliance process
Quality Control and Testing
Independent testing of CTR compliance is required as part of your BSA/AML program. Testing should include:
- Transaction sampling - Review sample of large currency transactions to verify CTR filing
- Aggregation testing - Test whether multiple transactions are properly aggregated
- Timeliness review - Confirm CTRs are filed within 15 days
- Data accuracy - Verify information on filed CTRs matches source records
- Exemption validation - Confirm designated exempt customers meet eligibility criteria
- Structuring detection - Test whether suspicious patterns are identified and escalated
✓ Independent Testing Requirement
BSA regulations require independent testing of your AML program, including CTR compliance, at least every 12-18 months depending on your risk profile. Testing can be conducted by internal audit (if independent of compliance function), third-party consultants, or external auditors.