Bank Secrecy Act (BSA) Regulations - Currency Transaction Reports (CTR)

Gregory J. Cook, EA, CPA+ Accredited Tax Advisor Past President Alabama Society of Enrolled Agents Past President Alabama Association of Accountants

An MSB must file a report of each currency transaction involving cash-in or cash-out of more than $10,000 conducted by, through, or to the MSB on any one day by or on behalf of the same person.

Therefore, a CTR is required when a transaction meets all of the following conditions:

*In currency,
*Greater than $10,000 in either cash-in or cash-out,
*By, or on behalf of, the same person, and
*Occurs on one business day.

Aggregation

Multiple transactions conducted by or on behalf of the same person on the same day are considered to be one transaction for CTR purposes. In other words, the MSB must file a CTR if it knows the customer’s aggregate cash-in or cash-out transactions total more than $10,000 in one day.


Cash-in and Cash-out

Cash-in transactions must be added together with cash-in transactions and cash-out transactions must be added together with cash-out transactions to determine whether the CTR threshold (greater than $10,000) has been met in any one business day.

CTR Filing

The CTR is IRS Form 4789, Currency Transaction Report, and is available on www.msb.gov or by calling the IRS Forms Distribution Center at 1-800-829-3676. The form must be filed within 15 days from the date of the transaction(s).

The CTR requirement requires and MSB to:

*Verify and record customer ID,
*Obtain transaction information,
*Complete and file the CTR,
*Retain a copy of the CTR for five years from the date of filing the report.

Keep Records

Monetary Instrument “Log” – for Cash Purchases of Money Orders, Traveler’s Checks, Other Instruments

An MSB that sells money orders, traveler’s checks, or other instruments for cash must verify the identity of the customer and create and maintain a record of each purchase when the purchase involves cash between $3,000 and $10,000, inclusive. Thus, a record is required when:

*Cash-in of $3,000-$10,000, inclusive, and
*Cash-in is for the purchase of money orders, traveler’s checks, or other monetary instruments.


The Monetary Instrument “Log” requirement requires an MSB to:

*Verify and record customer ID,
*Record transaction information (for each money order, traveler’s check, or other instrument purchased: amount, serial number, and date sold),
*Retain the record for five years from the date of the transaction.

Funds Transfer Rules For Senders of Money Transfers

An MSB that accepts an instruction to send a money transfer of $3,000 or more must verify the identity of the send customer and create and maintain a record of the money transfer, regardless of the method of payment.

In addition, certain information must “travel,” that is, the MSB must send on certain information, to the next MSB or financial institution processing the transfer.

For Receivers of Money Transfers

An MSB that accepts an instruction to pay a money order transfer of $3,000 or more must verify the identity of the receiving customer and create and maintain a record of the money transfer, regardless of the method of payment.

The requirement to record funds transfers requires a money transmitter to:

*Verify customer ID,
*Record customer information,
*Record transaction information,
*Send information to receiving MSB,
*Retain the record for five years from the date of the transaction.