FinCEN has been busy when it comes to CTRs as of late. You may recall that around September FinCEN updated their CTR FAQs but never formally communicated the changes to financial institutions and those changes conflicted with the CTR instructions. Not too long after that FinCEN updated their CTR XML Schema User Guide, also without notification, that made changes for reporting multiple transactions. While those issues are now resolved, we have even more CTR changes…that were, thankfully, adequately communicated.
FIN-2020-R001 makes significant changes on Currency Transaction Report (CTR) Form 112 for transactions involving sole proprietorships and legal entities operating under a “doing business as” (DBA) name. These changes are being made to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement… The changes are to be effective on April 6, 2020 (or September 1, 2020 for e-filing batch filers).
For more on these changes, be sure to check out the March 2020 edition of our Banking on BCC Magazine. We encourage you to review these changes with your applicable personnel as the effective date is quirky approaching.