FinCEN CTR Instructions - Does FinCEN provide examples for determining whether transactions meet the reporting threshold?

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Q:  Does FinCEN provide examples for determining whether transactions meet the reporting threshold?
 
A:  Yes.  Only cash transactions that, if alone or when aggregated, exceed $10,000 should be reported on the FinCEN CTR. Transactions shall not be offset against one another. If there are both Cash In and Cash Out transactions that are reportable, the amounts should be considered separately and not aggregated. However, they may be reported on a single FinCEN CTR. If there is a currency exchange, it should be aggregated separately with each of the cash in and cash out totals.
 
Example 1: A person deposits $11,000 in currency to his savings account and withdraws $3,000 in currency from his checking account. The FinCEN CTR should be completed as follows:
Item 25 “Total cash in” is $11,000, with no entry in Item 27 “Total cash out.” This is because the $3,000 transaction does not meet the reporting threshold.
 
Example 2: A person deposits $11,000 in currency to his savings account and withdraws $12,000 in currency from his checking account. The FinCEN CTR should be completed as follows:
Item 25 “Total cash in” is $11,000. Item 27 “Total cash out” is $12,000. This is because there are two reportable transactions. However, one FinCEN CTR may be filed to reflect both.
 
Example 3: A person deposits $6,000 in currency to his savings account and withdraws $4,000 in currency from his checking account. Further, he presents $5,000 in currency to be exchanged for the equivalent in Euro’s. The FinCEN CTR should be completed as follows:
Item 25 “Total cash in” is $11,000, with no entry in Item 27 “Total cash out.” This is because in determining whether the transactions are reportable, the currency exchange is aggregated with each of the Cash In and Cash Out amounts. The result is a reportable $11,000 cash in transaction. The total cash out amount is $9,000, which does not meet the reporting threshold. Therefore, the cash out amount is not entered on the FinCEN CTR.
 
Example 4: A person deposits $6,000 in currency to his savings account and withdraws $7,000 in currency from his checking account. Further, he presents $5,000 in currency to be exchanged for the equivalent in Euros. The FinCEN CTR should be completed as follows:
Item 25 “Total cash in” is $11,000. Item 27 “Total cash out” is $12,000. This is because in determining whether the transactions are reportable, the currency exchange is aggregated with each of the Cash In and Cash Out amounts. In this example, each of the Cash In and Cash Out totals exceeds $10,000 and must be reflected on the FinCEN CTR. The amount of Euros received in the currency exchange would be entered in Item 28 Foreign Cash Out.
 
This is addressed in the "FinCEN Currency Transaction Report Electronic Filing Requirements" guide, Attachment C, General Instruction #14.
 
 

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