A Currency Transaction Report (CTR) is a required report that financial institutions — including banks, broker-dealers, and casinos — must file with FinCEN (via FinCEN Form 112) whenever a customer conducts cash transactions totaling more than $10,000 in a single business day.
Key requirements: - Threshold: More than $10,000 in cash (not $10,000 exactly — the threshold is exceeded when the total is strictly greater than $10,000). - Applies to: All cash in and cash out transactions (deposits, withdrawals, currency exchanges, wire transfers paid in cash, currency used to purchase monetary instruments). - Filing deadline: The financial institution must file the CTR within 15 days of the transaction. - Who files: The financial institution — NOT the customer. The customer does not fill out the CTR.
Aggregation rule: All cash transactions by the same customer on the same business day must be aggregated. If a customer makes three separate $5,000 cash deposits in one day, all three are combined → $15,000 total → CTR required.
CTR exemptions: Certain customers can be exempted from CTR requirements (e.g., Phase I exempt persons — listed public companies, banks, government entities). Broker-dealers rarely use exemptions.
CTR ≠ Evidence of Wrongdoing: The CTR requirement is automatic for all cash transactions above $10,000 — it is not an accusation. However, structuring to avoid a CTR is itself illegal.
CTR vs. SAR: - CTR: automatic for cash >$10,000; customer may be aware. - SAR: triggered by suspicion; confidential (customer cannot be notified).
> Exam tip: CTR threshold = cash over $10,000; aggregate all same-day transactions. Filing deadline = 15 days. Structuring (breaking up transactions to avoid the CTR) is illegal. The financial institution files — not the customer.