The Currency Transaction Report (CTR) came into existence with the passage of the Currency and Foreign Transactions Reporting Act, better known as the Bank Secrecy Act (BSA), in 1970.
When the first version of the CTR was introduced the only way a suspicious transaction of less than $10,000 was reported to the government was if a bank teller called an agent and provided the information. This was due, primarily, to the concern by financial institutions about the Right to Financial Privacy. On October 26, 1986, with the passage of the Money Laundering Control Act, the Right to Financial Privacy was no longer an issue. As part of the Act, Congress had stated that a financial institution could not be held liable for releasing suspicious transaction information to law enforcement. As a result, the next version of the CTR had a suspicious transaction check box at the top. This was in effect until April 1996 when the Suspicious Activity Report (SAR) was introduced.
Currency reporting has changed since its introduction in 1970. There are now several different requirements for several different types of financial institutions as well as non-financial institutions.
The various currency forms, their reporting requirements, and the number filed in calendar year 2008 are shown in this chart:
Report |
Requirements |
Filed in CY 2008 |
Currency Transaction Report (CTR) |
Filed by financial institutions that engage in a currency transaction in excess of $10,000 |
15,449,549 |
Currency Transaction Report Casino (CTRC) (Includes both Form 8362 & Form 8852) |
Filed by a casino to report currency transactions in excess of $10,000. |
452,075 |
Report of Foreign Bank and Financial Accounts (FBAR) |
Filed by individuals to report a financial interest in or signatory authority over one or more accounts in foreign countries, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. |
349,667 |
IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business |
Filed by persons engaged in a trade or business who, in the course of that trade or business, receives more than $10,000 in cash in one transaction or two or more related transactions within a twelve month period. |
173,345 |
Suspicious Activity Report (SAR) |
Filed on transactions or attempted transactions involving at least $5,000 that the financial institution knows, suspects, or has reason to suspect the money was derived from illegal activities. Also filed when transactions are part of a plan to violate federal laws and financial reporting requirements (structuring) |
733,543 |
Suspicious Activity Report Casino (SARC) |
Filed on transactions or attempted transactions if it is conducted or attempted by, at, or through a casino, and involves or aggregates at least $5,000 in funds or other assets, and the casino/card club knows, suspects, or has reason to suspect that the transactions or pattern of transactions involves funds derived from illegal activities. Also filed when transactions are part of a plan to violate federal laws and transaction reporting requirements (structuring). |
11,162 |
Registration of Money Services Business (RMSB) |
Each Money Services Business (MSB), except one that is a money services business solely because it serves as an agent of another MSB, must register. |
21,263 |
Suspicious Activity Report by Money Services Businesses (SARM) |
Filed on transactions or attempted transactions if it is conducted or attempted by, at, or through a MSB, involving or aggregating funds or other assets of at least $2,000 in funds or other assets, and the MSB knows, suspects, or has reason to suspect that the transactions or pattern of transactions involves funds derived from illegal activities. Also filed when transactions are part of a plan to violate federal laws and transaction reporting requirements (structuring) or when the transaction has no business or apparent lawful purpose and the MSB know of no reasonable explanation for the transaction after examining the available facts. When transactions are identified from a review of records of money orders or travelers checks that have been sold or processed, an issuer of money orders of traveler's checks shall be required to report a transaction or a pattern of transactions that involves or aggregates funds or other assets of at least $5000. |
531,763 |
Suspicious Activity Report by the Securities & Futures Industries |
Filed on transactions, or attempted transactions, if it is conducted by, at, or through a broker-dealer, it involves aggregates funds or other assets of at least $5,000, and the broker-dealer knows, suspects, or has reason to suspect that the transaction involves funds derived from illegal activities or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity. Also filed when transactions are designed, whether through structuring or other means, to evade filing requirements. Also filed when transaction has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the broker-dealer knows of no reasonable explanation for the transaction after examining the available facts. Also filed when the transaction involves the use of the broker-dealer to facilitate criminal activity |
15,105 |
Designation of Exempt Person |
Used by bank or other depository institution to designate an eligible customer as an exempt person from currency transaction reporting rules. |
52,149 |
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