How Many Days Do You Have to File a CTR?

CTRs combat financial crimes like money laundering and terrorism financing. They are a component of the Bank Secrecy Act (BSA), which prevents illicit funds from entering the U.S. financial system. CTRs create a paper trail for law enforcement and regulatory bodies to investigate suspicious activities.

Understanding the Currency Transaction Report (CTR)

A Currency Transaction Report (FinCEN Form 104) is a document financial institutions file with the Financial Crimes Enforcement Network (FinCEN). Its purpose is to provide law enforcement with information about large cash transactions, which can indicate illicit financial activity. These reports help monitor currency flow and deter criminals from concealing gains through legitimate financial channels.

Financial institutions in the United States must file CTRs. This includes banks, credit unions, money services businesses, and casinos. CTRs are for transactions involving physical currency (coin and paper money).

When a CTR is Required

A CTR is required when a currency transaction exceeds $10,000. This applies to any single transaction involving physical cash, such as a deposit, withdrawal, exchange, or other payment. This helps track substantial cash movements linked to illegal activities.

The “aggregation rule” is a key aspect of CTR requirements. Financial institutions must treat multiple separate currency transactions by or on behalf of the same person during a single business day as a single transaction if their total exceeds $10,000. For instance, if a customer makes several cash deposits throughout a day that individually fall below the threshold but collectively surpass it, a CTR must be filed. This rule prevents “structuring,” where individuals break down large cash amounts into smaller transactions to evade reporting.

The Filing Deadline

Financial institutions must file a CTR within 15 calendar days following the transaction date. This is a strict requirement for Bank Secrecy Act compliance. The 15-day period begins the day after the transaction. For example, if a reportable cash transaction occurs on the first day of a month, the institution has until the 16th day to electronically submit the CTR to FinCEN. Adhering to this timeframe is important for regulatory compliance and avoiding penalties.

Preparing and Submitting a CTR

Preparing a CTR (FinCEN Form 104) involves gathering details about the transaction and individuals involved. This includes the full legal name, address, date of birth, and occupation of the person conducting the transaction. The Social Security Number or Taxpayer Identification Number, and the type and number of identification used to verify identity, are also required. If the transaction is on behalf of another person or entity, their identifying information must also be provided. Financial institution details, such as its name, address, and Employer Identification Number (EIN), are also necessary. The report must state the date, type, and total amount of the currency transaction, including currency denominations if applicable. Accurate and complete data entry is important for regulatory reporting and helps FinCEN identify financial crime patterns.

CTRs must be submitted electronically through the FinCEN BSA E-Filing System. Financial institutions must register with this system to gain access. The process involves logging in, selecting FinCEN Form 104, inputting the gathered information into designated fields, and submitting the report. Upon successful submission, filers receive a confirmation, which serves as proof of compliance. Electronic filing became mandatory for CTRs, replacing paper submissions.

Importance of Compliance and Recordkeeping

Compliance with CTR requirements includes timely filing and maintaining records. Financial institutions must retain copies of all filed CTRs and supporting documentation for five years from the report date. These records can be kept in electronic or paper format. This recordkeeping ensures a verifiable audit trail for regulatory review and investigations.

Failure to comply with CTR requirements can lead to consequences for financial institutions. Penalties for non-compliance, mandated by the Bank Secrecy Act, can range from civil money penalties to criminal charges for deliberate violations. Fines can be substantial, demonstrating the seriousness with which regulatory authorities view these failures. These penalties underscore the importance of accuracy, completeness, and timeliness in meeting CTR obligations.