A Currency Transaction Report (CTR) is a mandatory FinCEN filing for cash transactions exceeding $10,000 in a single business day.
Key Characteristics
| Aspect | Detail |
|---|---|
| Threshold | >$10,000 cash |
| Timing | Single business day |
| Trigger | Automatic—not based on suspicion |
| Aggregation | Multiple transactions by same person are aggregated |
CTR vs. SAR
| CTR | SAR |
|---|---|
| Routine reporting | Suspicious activity reporting |
| Threshold-based | Judgment-based |
| Cash transactions only | Any transaction type |
| Always required when threshold met | Required when suspicion exists |
Structuring
Structuring—breaking transactions into smaller amounts to avoid CTR thresholds—is itself a federal crime, even if the underlying funds are legitimate.
Example: Depositing $9,500 on three consecutive days to avoid a $10,000+ CTR.
CTRs and KYB
For KYB, CTR considerations include:
- Cash-intensive businesses (MSBs, casinos, retail) generate more CTRs
- High CTR volume may indicate higher AML risk
- Understanding expected CTR activity helps calibrate ongoing monitoring
CTRs are filed electronically through FinCEN’s BSA E-Filing system within 15 days.