FinCEN CTR Instructions – Who must file a CTR?

Compliance > BSA > FinCEN CTR Instructions
Q:  What is the deadline for filing a CTR?
A:  Each financial institution (other than the U.S. Postal Service, for which there are separate rules) must file a FinCEN CTR for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency of more than $10,000. Multiple transactions must be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of the same person and they result in either currency received (cash in) or currency disbursed (cash out) by the financial institution totaling more than $10,000 during any one business day. For a bank, a business day is the day on which transactions are routinely posted to customers’ accounts, as normally communicated to depository customers. The business day for casinos is based on the gaming day, which is the normal business day of the casino by which it keeps its books and records for business, accounting, and tax purposes. For all other financial institutions, a business day is a calendar day. Generally, financial institutions are defined as banks, other types of depository institutions, casinos and card clubs, brokers or dealers in securities, money transmitters, currency exchangers, check cashers, and issuers/sellers/payers of money orders and traveler’s checks. Only those casinos, gambling casinos, or card clubs in the United States that have gross annual gaming revenues in excess of $1 million are financial institutions for purposes of the FinCEN CTR. The FinCEN CTR should not be used to report receipts of currency in excess of $10,000 by any non-gaming businesses of a casino (e.g., a hotel). Instead, such transactions should be reported on Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. Casinos, gambling casinos, or card clubs with gross annual gaming revenues that are less than $1 million are not financial institutions for purposes of the FinCEN CTR and should report all transactions in currency greater than $10,000 on Form 8300. Additional information on financial institutions required to report currency transactions is found in 31 CFR Chapter X.
This is addressed in the "FinCEN Currency Transaction Report Electronic Filing Requirements" guide, Attachment C, General Instruction #1.

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