BSA/ AML Currency Transaction Report (CTR) Requirements and Exemptions

Learn the nuts and bolts of Currency Transaction Reporting and the processes and procedures for filing CTRs.

United States financial institutions are required to file Currency Transaction Reports for transactions involving more than $10,000. This requirement was created with the passage of the Bank Secrecy Act in 1970. Today, transactions of more than $10,000 are far more common. Customers may not understand why the bank is reporting information about their transactions to the government. This presentation will help banking executives, employees who interact with customers, and regulators regarding CTRs understand the history and rationale for the reporting requirements, the structure of the Bank Secrecy Act, and the important role banks play in combatting illicit finance.

Agenda

Overview and History of the Bank Secrecy Act

• Passage and Purpose of the BSA in 1970
• Developments to the BSA, From the Money Laundering Control Act in 1986 to the Anti-Money Laundering Act of 2020
• Relevant Statutes, Regulations, and Guidance
• Rationale for Recordkeeping and Reporting Requirements

Currency Transaction Reports and Exemptions

• What Must Be Filed?
• What Information Must Be Included?
• How Is the Information Used?
• Consequences for Failure to File

Processes and Procedures

• Process for Assessing Exemptions
• Recognizing and Reporting Structured Transactions
• What to Do If You Fail to File

Other Reporting Requirements

• Suspicious Activity Reports
• Other Reports