What is the Currency Transaction Report (CTR)?

In this blog post, we’ll be talking about currency transaction reports (CTRs). CTR is a report that should be filed by your company to the Financial Crimes Enforcement Network (FinCEN), a U.S. financial system protection regulatory body. This report is filed for cash transactions that exceed $10000 in a business day. To reach anti-money laundering (AML) compliance under the Bank Secrecy Act (BSA), you should be filing CTRs.

The History of the Currency Transaction Report

The CTR was introduced as a part of the Bank Secrecy Act in 1970. After seeing how 9/11 affected the U.S., this report’s role was strengthened to fight terrorism financing and making sure financial security is not compromised. Afterwards, CTR has become central to U.S. financial crime prevention.

What Is the Purpose of a Currency Transaction Report?

A CTR surely helps when recording large cash movements but its benefits don’t end there. CTRs are important for preventing structuring or smurfing; this act is done by people transferring large amounts of money to smaller transactions to avoid being detected by authorities. Another way CTRs help is by supporting law enforcement investigations; these records are providing important data when it comes to money laundering or different financial crime investigations. While achieving all this, filing CTRs is required to reach compliance with Bank Secrecy Act regulations.

What Is the $10,000 Rule?

The $10000 rule involves your company filing a CTR with FinCEN when one of your customers makes cash deposits, withdrawals, or other transactions of more than $10000 in a single day. Whether the money is moved in one big transaction or several smaller transactions, also known as smurfing, doesn’t matter, your company still has to report accordingly to make sure you reach compliance. 

The number of reports filed has increased by about 62% since fiscal year 2002. The reporting threshold hasn't been updated for inflation since it was set in the 1970s, which may have contributed to the increase. Using an inflation-adjusted threshold would have reduced the number of CTRs filed by at least 90% annually since 2014. 

CTR Filing Requirements

Since it is required by the Bank Secrecy Act, filing a CTR is no joke and comes with several requirements. Since we’ve talked about the $10000 rule, you should first think of filing the report after the amount of transactions in a single business day gets to that amount. The CTR should be filed electronically through the BSA E-Filing System. This filing has to be completed within 15 days of the transaction occurring. 

Our readers should remember to contain important details like identification information and transaction data involving the report, this will help the authorities in the process. Afterwards, your company should be keeping the records for at least five years; in the case of an investigation, these records will be needed. These requirements must be fulfilled to make sure they are supporting your company’s AML compliance program.

Who Is Required to File a Currency Transaction Report?

We’ll talk about the most common industries that are tasked with filing CTRs in 2025. Banks and credit unions are our first example; these companies work with high volumes of transactions and they should be extra careful during the process. Money service businesses (MSBs) are check-cashing outlets, money transmitters, and remittance firms; these are naturally dealing with huge sums of money and should file CTRs while also being registered to FinCEN to legally operate. 

Traditional banking institutions are not the only thing that needs to be on top of their reporting game, casinos are another example to this list. Casinos are required to do these reports if they generate $1 million yearly; large cash buy-ins and cash-outs that occur in casinos can be fruitful opportunities for money laundering. Securities brokers are another example and they should report accordingly since they monitor large amounts of cash securities purchases. Lastly, since they are growing rapidly, cryptocurrency firms are also included. If a crypto firm is registered as an MSB, they should file CTRs; this is especially important for their cash-to-crypto transactions that involve large amounts of money. 

The U.S. Department of Treasury,) issued a Geographic Targeting Order (GTO) through FinCEN in Marh 2025 that requires MSBs in counties along the southwest border to file CTRs on cash transactions between $200 and $10,000 and document identification of the individuals conducting the transactions.  The purpose of this action is said to be stopping cartels from money laundering and other financial crimes. This shows how certain providers and geographic locations may get more pressure for reporting during certain situations.

CTR vs. Suspicious Activity Report (SAR): Key Differences

We use both CTRs and SARs while trying to reach compliance within our own company and to fight against financial crimes, but what is so different about these reports? Firstly, while a CTR is needed after a $10000 transaction limit has been reached in a single day, SARs don’t have a specific dollar threshold that encourages the company to then report. CTRs are filed regardless of whether you think it is suspicious, unusual, or legitimate; SARs are filed when your company decides that there is suspicious activity occurring which could mean financial crimes. 

Customers are not formally notified when a CTR is filed but they may notice since they are surpassing the $10000 limit decided by the BSA; SARs, on the other hand, are confidential and companies are prohibited from letting the customer know. You have a 15 days deadline when filing a CTR; the limit is longer when filing a SAR, up to 30 days is allowed. Both reports are mandated by regulatory bodies. CTRs are there for keeping an eye on high amounts of cash usage, and SARs are dealing more so with detecting suspicious activities. 170 million CTRs were filed by banks between 2014-2023, per the Government Accountability Office and 4.6 million SARs were filed in 2023. 

What Are the Consequences of Failing to File a CTR?

We’ve talked about why filing a CTR is important, but what happens if you forget, or fail to do so? The first consequence you may face is fines, these can go up to $25000 for each violation depending on your case. If the case is extreme, you may face up to five years in prison, meaning criminal liabiliy is a potential risk for those who don’t file a CTR. 

Your company may get penalties like getting sanctioned by regulatory bodies, intensive audits caused by non-compliance, and overall heightened scrutiny, leading to more pressure on your company. Your reputation gets hurt the most; this reduced trust may lead to banks being more vary with your company, potentially losing customers from your company, and your licenses getting revoked.