What is the Currency Transaction Report (CTR)?

A Currency Transaction Report (CTR) is used by US financial institutions to help prevent money laundering. A bank employee must complete this form whenever a customer asks to deposit or withdraw money totaling more than $10,000. It limits the value of transactions and is a component of the banking sector's anti-money laundering (AML) responsibilities. Banks in the US use this form to add paperwork and protection to high-value transactions.

The Financial Crimes Enforcement Network (FinCEN) requires financial institutions in the US to submit a CTR for every deposit, withdrawal, currency exchange, and other payment or transfer that involves a currency transaction worth more than $10,000.

This law applies to cryptocurrency businesses as well. An operator of a cryptocurrency ATM must submit a CTR, for instance, if a customer attempts to buy bitcoin using more than $10,000 in cash from one of the operator's machines. Likewise, a cryptocurrency CTR must be filed if the company owner also runs a cryptocurrency exchange and a client attempts to sell more than $10,000 worth of bitcoin in one day. AML solutions for banks support them for CTRs, especially by keeping records in this world of big data.

Key Takeaways 

  • Any currency transaction that exceeds $10,000 must be reported to regulators using a Currency Transaction Report (CTR).
  • The CTR is a component of anti-money laundering measures to ensure that the money isn't being utilized for illegal or wrongful purposes.
  • CTRs are not required when banks, public businesses, or other governmental entities make significant transactions.

transaction laundering's role in facilitating illicit activities, and the preventive measures businesses can implement

The History of CTR

The Bank Secrecy Act established the concept of Currency Transaction Reports (1970). It established specific rules for when transactions must be recorded. Due to new laws, some entities are no longer required to report all transactions over $10,000 with a CTR.

The following are "exempt persons":

  • Any bank in the United States.
  • Any organization with government authority, including departments or agencies that are under the control of the federal, state, or municipal governments of the United States.
  • Any business whose shares are traded on the NYSE, Nasdaq, or AMEX (excluding stocks listed on the Emerging Company Marketplace and under the Nasdaq Small-Cap Issues heading).

When the CTR was implemented, only a banker's judgment could cause a transaction under $10,000 to be reported as suspicious. The banking sector's worry over the right to financial privacy was the reason behind this. However, with the passing of the Money Laundering Control Act in October 1986, the right to financial privacy was no longer a concern when reporting suspicious activity.

The US Congress mandated that a financial institution could not be held accountable for providing law enforcement agencies with information regarding suspicious transactions. The following iteration of CTR featured a suspicious transaction checkbox at the top. This would trigger a more thorough examination of the possibilities of money laundering. Formerly known as Form 104, the CTR form is now Fo FinCEN's E-filing system.

How should a CTR be submitted?

You must create a culture of compliance at your organization to maintain strong AML compliance. As a result, every employee must receive training on recognizing suspicious activity in transaction data and report it to the BSA Compliance Officer.

It is the BSA Compliance Officer's responsibility to decide if a CTR should be submitted and perform the filing, even though you may note the BSA Compliance Officer regarding a transaction you believe should trigger a CTR to be filed.

CTRs can be completed and filed online with FinCEN. The customer's name and all relevant customer data, such as their address, SSN, and business name, are required as a minimum. In addition, the BSA Compliance Officer must submit all CTRs on schedule.

The deadline for filing each report is different, with the CTR different from the SAR. Therefore, CTRs must be submitted within FinCEN's deadline after the transaction date.

Additionally, the BSA Compliance Officer must keep track of the CTRs it submits for a certain amount of time to provide them to authorities immediately upon request.

report meets the requirement of the AML Act of 2020 to provide

Transaction Structuring

"Structuring" refers to dividing these payments into smaller transactions to avoid detection.

Some clients informed of the $10,000 reporting obligation may decide to reduce the transaction size. Some people will divide the transaction into a number of smaller withdrawals or deposits. Despite these attempts, a SAR will be filed in many circumstances. It might result in criminal charges in some cases.

Structuring is illegal. Federal law considers the bank's obligation to submit a CTR to consider cumulative payments, even though each transaction does not exceed the $10,000 level. Therefore, any attempts to avoid reporting could lead to a criminal penalty.

The Importance of Currency Transaction Reports in AML

The US's anti-money laundering program heavily relies on CTRs. CTRs require financial institutions to confirm the identification and Social Security Numbers of consumers attempting a major transaction to prevent financial crimes. This standard still applies whether the customer has an account with the institution.

Financial institutions can use them to decide which transactions require serious monitoring. They aid in drawing attention to shady behavior and huge amounts of money being transferred by risky clients. This documentation procedure is also helpful for law enforcement when trying to track down financial criminals.

FAQs about Currency Transaction Reports

What is a CTR in banking?

The bank's anti-money laundering regulations require currency transactions above $10,000 to file a Currency Transaction Report or CTR.

Are Currency Transaction Reports private?

Without a request, banks are not required to inform clients about CTRs. This is not the same as a Suspicious Activity Report, which should not be shared with the client.

When should a Currency Transaction Report be filed?

Every time a consumer performs a currency transaction worth more than $10,000, or for many transactions, if the total exceeds $10,000 in a single day, CTRs must be filed.

What information must be included in a currency transaction report?

CTRs require institutions to verify the identification and Social Security Numbers of anybody trying a big transaction, whether or not that individual has an account with the institution, in order to avoid financial crimes.

What are AML Solutions for Banks?

When it comes to AML solutions in banking, the CTR plays a pivotal role in safeguarding financial institutions against money laundering activities. A Currency Transaction Report is a critical tool in the fight against financial crimes. US financial institutions are mandated to complete a CTR whenever a customer requests to deposit or withdraw an amount exceeding $10,000. This requirement is a cornerstone of the banking sector's AML responsibilities, aimed at adding a layer of scrutiny and documentation to high-value transactions.

They serve as a powerful tool for identifying and preventing money laundering activities, whether in traditional banking or the rapidly evolving realm of cryptocurrencies. By staying informed about the history and regulations surrounding CTRs and maintaining a culture of compliance, financial institutions can continue to strengthen their AML efforts and protect the financial system from illicit activities.

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