Currency Transaction Reporting (CTR) Filing Guide

Overview

Currency Transaction Reports (CTRs) are mandatory filings required by the Bank Secrecy Act (BSA) under 31 CFR 1010.310. Financial institutions must file CTRs with FinCEN when they conduct currency transactions exceeding $10,000. For trading platforms, cryptocurrency exchanges, money transmitters, and other money services businesses (MSBs), CTR compliance is a cornerstone of anti-money laundering (AML) obligations.

This comprehensive guide covers CTR thresholds, aggregation rules for multiple transactions, exemption eligibility, structured transaction detection, and the complete FinCEN filing process. Understanding and implementing proper CTR procedures is essential to avoid severe civil and criminal penalties.

⚠ Critical Compliance Requirement

Willful failure to file required 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). Additionally, structuring transactions to evade CTR requirements is itself a separate federal crime under 31 U.S.C. 5324.

$10,000 CTR Threshold

The fundamental rule: A CTR must be filed for each currency transaction exceeding $10,000. This threshold is established by 31 CFR 1010.310 and applies to transactions conducted by, through, or to the financial institution.

What Qualifies as "Currency"?

For CTR purposes, "currency" has a specific legal definition:

Coin and paper money of the United States or any other country that is designated as legal tender and circulates as a medium of exchange
Cashier's checks, bank drafts, traveler's checks, or money orders with a face value of $10,000 or less, when received in certain designated reporting transactions

⚠ Cryptocurrency and CTRs

Cryptocurrency itself is NOT considered "currency" for CTR filing purposes under current FinCEN guidance. However, when customers convert cryptocurrency to U.S. dollars or other fiat currency exceeding $10,000 in cash, the fiat portion may trigger CTR requirements. This area continues to evolve, so monitor FinCEN guidance for updates.

Single Transaction Rule

If a single currency transaction exceeds $10,000, a CTR is required regardless of any other factors.

Example 1: Simple Single Transaction

Scenario: Customer deposits $15,000 cash into their trading account on Monday at 2:00 PM.

Analysis: Single transaction exceeds $10,000 threshold.

Required Action: File CTR within 15 calendar days of transaction date.

Filing Deadline: 15 days from transaction date.

Aggregation Rules for Multiple Transactions

Financial institutions must aggregate all currency transactions conducted by or on behalf of the same person during a single business day. If the aggregated total exceeds $10,000, a CTR must be filed even though no individual transaction exceeded the threshold.

Key Aggregation Principles

Same person: All transactions by or on behalf of the same individual or entity
Single business day: All transactions occurring within one business day (not calendar day for aggregation purposes)
Knowledge standard: Institution must aggregate when it has knowledge or should have knowledge that transactions are related
Multiple locations: Aggregation applies even if transactions occur at different branches or locations of the same institution

Example 2: Multiple Deposits - Same Day Aggregation

Scenario: Customer John Smith makes the following transactions on Tuesday:

9:00 AM - Deposits $4,500 cash at Branch A
1:00 PM - Deposits $3,800 cash at Branch B
4:30 PM - Deposits $2,200 cash at Branch A

Total Aggregated Amount: $10,500

Analysis: Although no single transaction exceeds $10,000, the aggregated total for the business day exceeds the threshold.

Required Action: File CTR for John Smith showing $10,500 in aggregated deposits.

Knowledge Standard for Aggregation

The obligation to aggregate transactions depends on your institution's knowledge. Knowledge includes:

Actual knowledge: You definitively know the transactions are conducted by or on behalf of the same person
Should have known: Based on the facts and circumstances, a reasonable financial institution would conclude the transactions are related
Constructive knowledge: Information available in your records or systems indicates the transactions are related
Willful blindness: Deliberately avoiding knowledge to circumvent CTR requirements (this is illegal)

⚠ "Should Have Known" Standard

Courts have consistently held that financial institutions cannot deliberately ignore obvious patterns to avoid CTR filing obligations. If multiple transactions bear clear indicia of being conducted by the same person (e.g., same IP address, linked accounts, family members, similar transaction patterns), you may be required to aggregate them even without explicit confirmation of the relationship.

Example 3: Related Party Aggregation

Scenario: On the same business day:

ABC Corporation (EIN 12-3456789) deposits $6,000 cash
Jane Doe (listed as CEO of ABC Corp in KYC records) deposits $5,500 cash into her personal account

Analysis: Your KYC records show Jane Doe is CEO of ABC Corp. You have knowledge that these parties are related.

Total Aggregated Amount: $11,500

Required Action: File CTR noting both individuals and the relationship between them.

CTR Aggregation Decision Tree

Should You File a CTR? Follow This Decision Tree

Step 1: Is the transaction in "currency" as defined by BSA?

Currency = cash (coin/paper money) OR cashier's checks, money orders, traveler's checks under $10K in designated transactions

If NO → No CTR required (but consider other reporting obligations)

If YES → Continue to Step 2

Step 2: Does a single transaction exceed $10,000?

If YES → Skip to Step 4 (CTR likely required)

If NO → Continue to Step 3

Step 3: Do multiple transactions by/for the same person aggregate to over $10,000 in a single business day?

Review all currency transactions by the same customer on the business day

Include transactions at all branches/locations

Consider related parties if you have knowledge of relationships

If YES → Continue to Step 4

If NO → No CTR required

Step 4: Is the customer exempt from CTR filing?

Check if customer falls into an exempt category (bank, government agency, listed company)

Verify that exemption has been properly filed with FinCEN (Form 110)

If YES (properly exempt) → No CTR for this transaction; maintain exemption documentation

If NO → Continue to Step 5

Step 5: FILE CTR within 15 calendar days of the transaction date

CTR Exemptions

Certain categories of customers may be exempt from CTR reporting under 31 CFR 1010.315. However, exemptions are NOT automatic—they must be formally designated and filed with FinCEN using Form 110 (Designation of Exempt Person).

Exempt Customer Categories

Exemption Category	Description	Filing Requirements
Banks and Credit Unions	Domestic banks, savings associations, credit unions, federal branches, and agencies of foreign banks	Automatic exemption; no Form 110 filing required
Government Entities	Federal, state, local, or foreign government departments, agencies, or instrumentalities	Must file Form 110 to designate exemption
Listed Public Companies	Corporations whose stock is traded on a U.S. national securities exchange (NYSE, NASDAQ, etc.)	Must file Form 110; verify current listing status
Subsidiaries of Listed Companies	Wholly-owned domestic subsidiaries of listed public companies	Must file Form 110; verify ownership structure (100% ownership required)
Non-Listed Businesses	Qualifying businesses that meet specific eligibility criteria but are not publicly traded	Must file Form 110; biennial review required; must meet account and transaction history requirements
Payroll Customers	Customers who maintain accounts and regularly withdraw currency for payroll purposes	Must file Form 110; document legitimate payroll purpose

⚠ Exemptions Apply Only to CTRs

CTR exemptions do NOT exempt customers from other BSA requirements, including Suspicious Activity Report (SAR) obligations. Even if a customer is exempt from CTR filing, you must continue to monitor their transactions for suspicious activity and file SARs when warranted. An exemption means "don't file CTRs for routine large transactions"—not "ignore this customer's activity."

Non-Listed Business Exemption Eligibility Criteria

A non-publicly traded business may qualify for exemption if it meets ALL of the following criteria:

Has maintained a transaction account at your institution for at least 2 months
Frequently engages in currency transactions exceeding $10,000 (no precise definition, but typically means regular/recurring pattern)
Is incorporated or organized under the laws of the United States or a state, OR operates and maintains a physical presence in the United States
Operates a retail-type business or provides professional services (e.g., law firm, accounting firm)
Is NOT engaged in illegal activity or raising red flags for suspicious behavior
Has provided satisfactory evidence of its business operations and legitimacy

💡 Exemption Due Diligence

Before designating a non-listed business as exempt, conduct thorough due diligence: verify business registration, review transaction history, assess the business's legitimacy, and ensure there are no suspicious activity concerns. Exempting a business engaged in money laundering exposes your institution to severe liability.

Filing and Maintaining Exemptions

To properly designate and maintain CTR exemptions:

Verify eligibility: Ensure the customer meets all criteria for the applicable exemption category
Complete due diligence: Document the basis for the exemption and verify required information
File FinCEN Form 110: Electronically submit Designation of Exempt Person through BSA E-Filing system
File within 30 days: Initial exemption designation must be filed within 30 days of designating the customer as exempt
Biennial review: Review exemption status every two years and file updated Form 110 confirming continued eligibility
Monitor continuously: If customer's status changes (e.g., delisting from exchange, change in ownership, suspicious activity), immediately revoke exemption and file CTRs for subsequent transactions
Maintain records: Keep all exemption documentation for 5 years after exemption termination

Structuring vs. Legitimate Transactions

"Structuring" (also called "smurfing") is the practice of conducting multiple currency transactions in amounts designed to evade CTR reporting requirements. Structuring is a federal crime under 31 U.S.C. 5324, even if the underlying funds are completely legitimate.

Legal Definition of Structuring

A person commits structuring when they:

Conduct or attempt to conduct one or more transactions in currency
In any amount
For the purpose of evading the requirement that financial institutions file CTRs

Critically, structuring is a crime even when the money is legally obtained. Intent to evade CTR reporting is the crime—not the source of funds.

⚠ Structuring is a Federal Crime

Under 31 U.S.C. 5324, structuring is punishable by up to 5 years in federal prison and fines up to $250,000 for individuals ($500,000 for organizations). If structuring is connected to another crime (like drug trafficking), the penalty increases to up to 10 years imprisonment. Additionally, structured funds are subject to civil forfeiture.

Example 4: Classic Structuring

Scenario: Customer has $25,000 in cash from selling a vehicle. To avoid "government reporting," the customer makes the following deposits over three consecutive days:

Monday: $8,000 cash deposit
Tuesday: $8,500 cash deposit
Wednesday: $8,500 cash deposit

Analysis: This is structuring. The customer intentionally broke up a legitimate $25,000 transaction into smaller amounts specifically to stay below the $10,000 CTR threshold.

Consequence: Federal crime. The financial institution must file a Suspicious Activity Report (SAR) immediately. Customer may face criminal prosecution and forfeiture of the funds.

Red Flags of Structuring Activity

Structuring Red Flags to Monitor

Multiple currency deposits or withdrawals just below $10,000 (e.g., $9,000, $9,500, $9,800)
Customer conducts transactions at multiple branches or ATMs on the same day, each below $10,000
Customer declines to complete a transaction or reduces the amount after learning it will trigger a CTR
Customer asks staff about CTR thresholds, reporting requirements, or how to avoid triggering reports
Pattern of transactions that consistently fall just below $10,000 with no clear business rationale
Customer uses multiple accounts or enlists other people (family, friends, employees) to conduct related transactions below the threshold
Transaction frequency increases as amounts approach but don't exceed $10,000
Customer appears nervous, evasive, or reluctant to provide identification when transaction approaches threshold
Transactions lack economic rationale given the customer's known business or employment
Customer requests unusual services like purchasing multiple cashier's checks in amounts under $10,000

Distinguishing Structuring from Legitimate Business Patterns

Not every pattern of transactions below $10,000 is structuring. Many legitimate businesses naturally conduct regular transactions below the threshold based on their normal business operations.

Example 5: Legitimate Business Pattern (NOT Structuring)

Scenario: A local restaurant deposits cash receipts from daily operations, Monday through Friday:

Monday: $3,100 (typical Monday receipts)
Tuesday: $2,900 (typical Tuesday receipts)
Wednesday: $3,600 (typical Wednesday receipts)
Thursday: $4,300 (typical Thursday receipts)
Friday: $8,700 (typical Friday receipts, busiest night)

Analysis: This pattern reflects the restaurant's actual daily business receipts. Amounts vary naturally based on daily customer volume. There is no evidence the restaurant is manipulating deposit amounts to avoid CTR requirements—this is simply the natural flow of their cash business.

Conclusion: NOT structuring. However, the financial institution should document the business rationale in its records and continue monitoring for any changes in pattern that might indicate structuring.

Responding to Suspected Structuring

If you suspect a customer is structuring transactions:

Do NOT tip off the customer: Federal law (31 U.S.C. 5318(g)(2)) prohibits disclosing to the customer that you suspect structuring, that you will file a SAR, or that they are under investigation. "Tipping off" is itself a federal crime.
Complete the transaction: Process the transaction as requested (unless other grounds exist to refuse it, such as fraud). Do not refuse transactions solely because you suspect structuring.
Document your suspicions: Create detailed internal records documenting the facts that lead you to suspect structuring
File a SAR: Submit a Suspicious Activity Report to FinCEN within 30 days of detecting the suspicious activity
File CTRs if applicable: If any single transaction or daily aggregate exceeds $10,000, you must still file the required CTR in addition to the SAR
Consider filing CTRs even for structured transactions: Some institutions file CTRs for the aggregated structured amounts as an additional compliance measure, though this is not always required
Continue monitoring: Enhanced monitoring of the customer's future activity

CTR Filing Deadlines

CTRs must be filed within 15 calendar days after the date of the transaction. This is a strict, non-negotiable deadline.

⚠ No Extensions Available

Unlike Suspicious Activity Reports (SARs), which may have extension procedures in certain circumstances, there is NO extension mechanism for CTR filing deadlines. Late filings constitute violations and may result in civil money penalties and regulatory enforcement actions.

Business Day vs. Calendar Day

Concept	Definition	Application in CTR Context
Business Day	A day the financial institution is open for carrying on substantially all of its business functions	Used for aggregation purposes: Aggregate all currency transactions within a single business day
Calendar Day	Every day of the year, including weekends and federal holidays	Used for filing deadline: Must file CTR within 15 calendar days from transaction date (weekends and holidays count)

Filing Deadline Calculation Example

Transaction Date: Monday, January 10, 2025

Calculation: Add 15 calendar days (includes weekends and holidays)

Filing Deadline: Tuesday, January 25, 2025 (Day 15)

Note: Even if January 25 falls on a weekend or holiday, the deadline does not extend. Plan to file before the deadline to account for potential system downtime or filing issues.

CTR Filing Checklist

Pre-Filing Checklist: Complete Before Filing Each CTR

Verify transaction amount exceeds $10,000 (single transaction or properly aggregated total)
Confirm transaction involves "currency" as defined by BSA regulations
Check if customer is properly designated as exempt (review Form 110 records)
Collect complete customer identification information (name, TIN, address, DOB, ID document)
For businesses: Obtain legal entity name, EIN, business address, and nature of business
Document whether customer conducted transaction on own behalf or for another person
If multiple persons involved, collect information for each person
Record transaction type (deposit, withdrawal, exchange, payment, etc.)
Note date and time of transaction(s)
Identify account numbers affected by the transaction
For aggregated transactions, document each component transaction and aggregation rationale
Verify BSA E-Filing System access is current and functional
Confirm filing will be completed within 15-day deadline

Form Completion Guide: FinCEN CTR (Form 112)

CTRs are filed electronically using FinCEN Form 112 (Currency Transaction Report) through the BSA E-Filing System. The form has multiple parts collecting detailed information about the transaction and the parties involved.

FinCEN Form 112: Section-by-Section Guide

Part I: Person(s) Involved in Transaction

Complete for each person on whose behalf the transaction is conducted:

Individual Last Name / Entity Name: Full legal name
First Name: (For individuals only)
Middle Initial: (For individuals only)
Doing Business As (DBA): If applicable
TIN Type: Select SSN (individuals), EIN (businesses), ITIN, or Foreign
Taxpayer Identification Number: 9-digit SSN or EIN
Address: Permanent street address (not P.O. Box for primary address)
City, State, ZIP: Complete address information
Country: If foreign address
Date of Birth: (For individuals only, MM/DD/YYYY format)
Identification Type: Driver's license, passport, state ID, etc.
Identification Number: Number from the identification document
Issuing State/Country: For the identification document
Occupation / Type of Business: Customer's occupation or nature of business

Part II: Person(s) Conducting Transaction (if different from Part I)

Complete if someone other than the beneficial owner conducted the transaction:

Same information as Part I (name, TIN, address, DOB, ID)
When to complete: Agent conducting on behalf of principal, employee conducting for employer, attorney conducting for client, etc.

Part III: Amount and Type of Transaction(s)

Date of Transaction: MM/DD/YYYY format
Total Cash In: Total amount of currency deposited, received, or exchanged
Total Cash Out: Total amount of currency withdrawn, paid out, or exchanged
Type of Transaction: Check all that apply:
- Deposits / Withdrawals
- Payment(s) / Transfer(s)
- Currency Exchange
- Other (specify)
Foreign Currency Involved: If yes, specify type and amount
Account Number(s) Affected: List all relevant account numbers

Part IV: Financial Institution Where Transaction Occurred

Legal Name of Institution: Registered business name
EIN: Financial institution's Employer Identification Number
Address: Primary business address
Type of Financial Institution: Select category (MSB, bank, broker-dealer, etc.)
If MSB, check type: Money transmitter, currency exchanger, check casher, etc.

Part V: Contact for Assistance

Contact Name: Person who can answer questions about this CTR
Phone Number: Contact phone number
Date Filed: Auto-populated by BSA E-Filing System

💡 Multiple Persons in Single CTR

If a transaction is conducted by or on behalf of more than one person (e.g., joint account holders each depositing cash), complete a separate individual section for EACH person. For example, if two joint account holders each deposit $6,000 on the same day (totaling $12,000), the CTR must include information for both individuals.

FinCEN Electronic Filing Process

All CTRs must be filed electronically through FinCEN's BSA E-Filing System. Paper CTR filings are no longer accepted.

BSA E-Filing System Registration

E-Filing System Setup Steps

Navigate to https://bsaefiling.fincen.treas.gov/
Click "Enroll" to create new institutional account
Provide financial institution information (legal name, EIN, address, type)
Designate primary E-Filing contacts (typically Compliance Officer and BSA Officer)
Designate supervisory users (those who can submit filings on behalf of institution)
Complete identity verification process (may require documentation)
Set up multi-factor authentication for account security
Download BSA E-Filing software (if using desktop application) OR bookmark web portal
Conduct test filing with sample CTR to ensure system access works correctly
Establish internal workflow for CTR preparation, review, and approval before filing
Set up automated calendar reminders for 15-day filing deadlines

Filing Method Options

Filing Method	Best For	Technical Requirements
Batch Filing (XML Upload)	High-volume institutions filing dozens or hundreds of CTRs monthly	Requires technical integration; generate XML files from transaction monitoring system; upload via BSA E-Filing
Web-Based Form Entry	Low-volume filers with occasional CTRs (e.g., small MSBs, niche platforms)	Manual data entry through web browser; no software download required; accessible from any internet connection
BSA E-Filing Desktop Software	Mid-volume filers (several CTRs per month)	Download free desktop application from FinCEN; save draft CTRs locally; submit when ready

Filing Confirmation and Tracking

After submitting a CTR electronically:

Immediate Acknowledgment: BSA E-Filing System provides instant confirmation that your submission was received
BSA Identifier (BSA ID): Each filed CTR receives a unique identifier for tracking and reference purposes
Acceptance Status: Check filing status within 1-2 business days to confirm FinCEN accepted the filing (vs. rejecting for errors)
Rejection Notices: If rejected due to data errors or missing information, correct the errors and re-file immediately—original 15-day deadline still applies
Acknowledgment Documentation: Save confirmation emails and BSA IDs as part of your recordkeeping

⚠ Plan for System Downtime

BSA E-Filing System undergoes periodic scheduled maintenance, typically on Sunday mornings. Do NOT wait until the last day of your 15-day filing deadline to submit CTRs. System outages, maintenance windows, or technical issues could prevent timely filing. Best practice: File CTRs within 10-12 days of transaction date to allow buffer time for any issues.

CTR Recordkeeping Requirements

Financial institutions must maintain copies of all filed CTRs and supporting documentation for five years from the date of filing, as required by 31 CFR 1010.430.

Required Records

Filed CTRs: Complete copy of each CTR submitted to FinCEN (PDF or electronic record)
Supporting transaction documentation: Account statements, deposit slips, withdrawal records, wire transfer documentation
Customer identification records: Copies of identification documents used to verify customer information on CTR
Aggregation analysis: Documentation showing how multiple transactions were identified as related and aggregated
Exemption files: For exempt customers, copies of Form 110 filings, biennial review documentation, and ongoing monitoring records
Filing confirmations: BSA Identifiers, acceptance notices, and acknowledgment emails from FinCEN
Internal communications: Emails, notes, or memos discussing CTR filing decisions, aggregation determinations, or exemption considerations

Recordkeeping Best Practices

Centralized filing system: Maintain all CTRs in a searchable database or document management system separate from general customer files
Index by multiple criteria: Enable search by customer name, date, transaction amount, BSA ID, and account number
Link to source transactions: Create electronic links between filed CTRs and the underlying transaction records in your core systems
Secure access controls: Limit access to CTR records to compliance personnel, BSA Officer, auditors, and authorized executives
Backup and redundancy: Maintain redundant copies of CTR records (cloud backup, offsite storage) to prevent loss due to system failures
Audit trail: Log all access to CTR records for examination purposes

⚠ Examination Scrutiny

During BSA/AML examinations, regulators routinely test CTR compliance by sampling large currency transactions from your records and verifying that required CTRs were filed timely and accurately. Inability to produce CTR records, failure to demonstrate proper aggregation procedures, or missing filings are among the most common and serious examination deficiencies.

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
Customer identification records (for CTR)	5 years	From date of transaction
Exemption designation (Form 110)	5 years	From date exemption terminated or revoked
Aggregation analysis and work papers	5 years	From date of analysis
BSA E-Filing confirmations	5 years	From date of filing

Exemption Eligibility Analysis

Use this framework to determine whether a customer qualifies for CTR exemption:

Exemption Eligibility Decision Framework

Question 1: What type of entity is the customer?

Bank or credit union → Automatically exempt (no Form 110 required)

Government entity → Proceed to Question 2

Listed public company → Proceed to Question 3

Subsidiary of listed company → Proceed to Question 4

Non-listed business → Proceed to Question 5

Individual or non-qualifying entity → NOT eligible for exemption

Question 2: Government Entity Exemption

Is it a federal, state, local, or foreign government department, agency, or instrumentality?

If YES → File Form 110; customer is exempt

If NO → NOT eligible for exemption

Question 3: Listed Public Company Exemption

Is the company's stock traded on a U.S. national securities exchange (NYSE, NASDAQ, etc.)?

Verify current listing status through exchange website or SEC EDGAR

If YES → File Form 110; customer is exempt

If NO or DELISTED → NOT eligible for exemption (revoke if previously exempt)

Question 4: Subsidiary Exemption

Is the customer a wholly-owned (100%) domestic subsidiary of a listed public company?

Verify ownership structure through corporate documents

Must be U.S.-based subsidiary with 100% ownership by listed parent

If YES → File Form 110; customer is exempt

If less than 100% ownership or foreign subsidiary → NOT eligible for exemption

Question 5: Non-Listed Business Exemption

Does the business meet ALL of the following criteria?

Maintained transaction account for at least 2 months
Frequently conducts currency transactions over $10,000
Incorporated/organized under U.S. law OR operates with physical U.S. presence
No suspicious activity or red flags
Legitimate retail business or professional service provider

If ALL criteria met → File Form 110; customer is exempt (subject to biennial review)

If any criteria NOT met → NOT eligible for exemption

Once exemption is approved: Monitor continuously and conduct biennial review every 2 years

Disclaimer: This guide provides general educational information about Currency Transaction Reporting (CTR) requirements under the Bank Secrecy Act and FinCEN regulations. It is not legal advice and does not create an attorney-client relationship. CTR requirements are complex, fact-specific, and subject to regulatory interpretation. Requirements may vary based on your specific business model, customer base, jurisdiction, and regulatory classification. This guide does not substitute for professional legal counsel. You should consult with qualified BSA/AML attorneys and compliance professionals to ensure your CTR compliance program meets all applicable federal and state requirements and is appropriately tailored to your institution's risk profile.