Currency Transaction Reporting
FFIEC BSA/AML Examination Manual 2 February 2021
card. In each instance, the specific identifying information (e.g., the driver’s license number)
used in verifying the identity of the customer must be recorded on the report. The mere notation
of “known customer” or “bank signature card on file” on the report is prohibited.
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Aggregation of Currency Transactions
For the purposes of currency reporting requirements, a bank includes all of its domestic branch
offices
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and, therefore, branch office transactions must be aggregated. Multiple currency
transactions resulting in either cash in or cash out totaling more than $10,000 during any one
business day must be treated as a single transaction, if the bank has knowledge that they are
conducted by or on behalf of any person. Deposits made at night or over a weekend or holiday
must be treated as if received on the next business day following the deposit.
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To comply with
regulatory requirements, management must ensure that systems or practices appropriately
aggregate currency transactions throughout the bank and report currency transactions subject to
the BSA requirement to file CTRs.
Types of currency transactions subject to reporting requirements individually or by aggregation
include, but are not limited to: deposits and withdrawals, automated teller machine (ATM)
transactions, denomination exchanges, loan payments, currency transactions used to fund
individual retirement accounts (IRAs), purchases of certificates of deposit, funds transfers paid
for in currency, monetary instrument purchases, certain transactions involving armored car
services,
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and currency to or from prepaid access.
In cases where multiple businesses share a common owner, FinCEN guidance
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states that the
presumption is that separately incorporated entities are independent persons. This FinCEN
guidance indicates that the currency transactions of separately incorporated businesses should
not automatically be aggregated as being on behalf of any one person simply because those
businesses are owned by the same person. It is up to the bank to determine, based on
information obtained in the ordinary course of business, whether multiple businesses that share a
common owner are, in fact, being operated independently depending on all the facts and
circumstances. Consistent with this FinCEN guidance, if the bank determines that the businesses
are independent, then the common ownership does not require aggregation of the separate
transactions of these businesses.
However, if the bank determines that these businesses (or one or more of the businesses and the
private accounts of the owner) are not operating separately or independently of one another or
their common owner (e.g., the businesses are staffed by the same employees and are located at
the same address, the bank accounts of one business are repeatedly used to pay the expenses of
another business, or the business bank accounts are repeatedly used to pay the personal expenses
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31 CFR 1010.312.
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31 CFR 1010.313(a).
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31 CFR 1010.313(b).
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For additional information on CTR filing requirements for transactions conducted through armored car services,
refer to FinCEN (July 12, 2013), FIN-2013-R001 “
Treatment of Armored Car Service Transactions Conducted on
Behalf of Financial Institution Customers or Third Parties for Currency Transaction Report Purposes.”
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FinCEN (March 16, 2012), FIN-2012-G001 “Currency Transaction Report Aggregation for Businesses with
Common Ownership.”