FinCEN Revises CTR Instructions Again

In our November 2019 Magazine, we informed you of the fact that FinCEN had changed their Currency Transaction Report instructions (CTR XML Schema User Guide) and the corresponding answer to Question #16 in their CTR FAQs, in regard to reporting a conductor in Part I when more than one role applies to that conductor.

We have since learned that FinCEN updated their CTR XML Schema User Guide again, without public notice.  This change relates to completing the Multiple Transaction box in Part I. Initially, FinCEN’s instructions stated that “multiple transactions” include ALL transactions, even if they were not reportable. FinCEN’s example under the previous instructions stated:

Item 3 Multiple transactions: 
If a customer makes a $12,000 deposit and a $300 withdrawal, box 3 will be checked even though only $12,000 is reportable. This applies when multiple Part I sections with different Item 2 person types are filed on the same person. Box 3 will be checked in all Part I sections on that person. 

The revised instructions have reversed that position and they now state:

Item 3 Multiple transactions:
Check Item 3 if multiple cash transactions of any amount totaling more than $10,000 as cash in or more than $10,000 as cash out (cash in and cash out transactions should not be combined) were conducted in a single business day by or for the person recorded in Part I. For example, if a customer makes a $12,000 deposit and a $300 deposit on the same day, item 3 should be checked. However, if a customer makes a $12,000 deposit and $300 withdrawal, item 3 should not be checked. Item 3 “Multiple transactions” is related to, but not the same as, the Item 24 “Aggregated transactions.” Whereas Item 3 should be checked each time multiple transactions are reported as a single transaction, the Item 24 option “Aggregated transaction” should only be checked when all the specific conditions underlying that option have been satisfied.

Make sure you share this information with those personnel in your institution that are responsible for completing CTRs.

For more information on these threshold changes, refer to the January 2020 edition of our Banking on BCC Magazine.

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