Q: How do I complete the FinCEN CTR for purchases of monetary instruments with currency?
A: Banks may implement a policy requiring customers who are deposit accountholders and who want to purchase monetary instruments with currency to first deposit the currency into their deposit accounts (while treating this two-step process as one transaction). Nothing within the BSA or its implementing regulations prohibits a bank from instituting such a policy. Therefore, if a customer purchases a monetary instrument using $15,000 in currency that the customer first deposits into the customer’s account, whether at the requirement of the bank or at the customer’s discretion, the financial institution would complete Part I of the FinCEN CTR with the customer’s information. In Part II Item 25, the financial institution would indicate $15,000 as cash in for Item 25d “Purchase of negotiable instrument(s)” as shown below. Completing the FinCEN CTR in this manner will notify law enforcement that the currency was used to purchase a negotiable instrument.
FAQs associated with Part III of the FinCEN CTR
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: