Currency Transaction Report
A Currency Transaction Report (CTR) is a mandatory Bank Secrecy Act report that US financial institutions must file with FinCEN whenever a customer conducts cash transactions totaling more than $10,000 in a single business day, regardless of whether the institution suspects illegal activity.
The CTR requirement was one of the original pillars of the Bank Secrecy Act of 1970 and represents an automatic, threshold-based reporting obligation distinct from the suspicion-based SAR regime. The logic behind the $10,000 threshold — which has never been adjusted for inflation since its 1970 establishment — is that large cash transactions are disproportionately associated with tax evasion, drug trafficking, and other crimes relative to the total legitimate need for cash transactions of that size in the modern economy.
CTRs are filed on FinCEN Form 114 (now electronically through BSA E-Filing) within 15 calendar days after the day the reportable transaction occurs. The form captures identifying information about the person conducting the transaction and any person on whose behalf the transaction is conducted, the financial institution and specific branch involved, the date, amount, and type of transaction, and whether the funds were deposited, withdrawn, exchanged, or transferred. Financial institutions are required to record and verify the identity of customers conducting CTR-triggering transactions.
The aggregation rule is important: multiple cash transactions with the same person in a single business day must be aggregated to determine whether the $10,000 threshold is crossed. A customer who makes three cash deposits of $4,000 each on the same day has conducted $12,000 in cash transactions and triggers a CTR obligation, even though no single transaction exceeded the threshold. Structuring — deliberately breaking up transactions to stay below the CTR threshold and avoid reporting — is itself a federal crime under 31 U.S.C. Section 5324, punishable by fines and up to 5 years imprisonment regardless of whether the underlying funds are from lawful sources.
The CTR exemption program under 31 CFR Part 1020.315 allows banks to exempt certain customers from routine CTR filing — primarily established businesses whose cash-intensive operations are well understood and documented. Eligible exemptions include Phase I exemptions for banks and publicly traded companies and Phase II exemptions for non-listed businesses and payroll customers. Institutions granting exemptions must conduct annual reviews and maintain documentation supporting the exemption determination.
Financial institutions filed over 17 million CTRs with FinCEN in fiscal year 2022, constituting an enormous volume of financial data that law enforcement uses primarily as a retrospective investigative tool. Because CTR filings are not disclosed to the subject, they serve as a silent record of cash activity that can be cross-referenced against tax returns, asset disclosures, and other records during investigations.