Currency transaction report (CTR)

A currency transaction report is the filing that banks and broker-dealers submit to the Financial Crimes Enforcement Network (FinCEN) when a customer moves more than $10,000 in currency — physical cash or coin — into or out of an account on a single business day. The report captures the customer's identity, the account involved, and the amount and nature of the transaction.

The threshold is applied on an aggregated daily basis, not per transaction. Three separate $4,000 cash deposits by the same customer on the same day total $12,000 and trigger a report. Because the filing is automatic and mechanical, a CTR carries no implication that the customer did anything wrong; most reports involve entirely legitimate cash-intensive businesses.

Deliberately breaking up cash activity to stay under the threshold is called structuring, and it is itself a federal crime. A representative who advises a customer on how to avoid triggering a CTR has violated anti-money-laundering rules regardless of where the money came from. Suspicious activity of that kind is reported separately on a suspicious activity report (SAR), which — unlike a CTR — may not be disclosed to the customer.

Currency transaction reports come out of the Bank Secrecy Act and the USA PATRIOT Act, which require every firm to maintain a written anti-money-laundering program with a designated compliance officer, ongoing training, and independent testing. Supervisory exams such as the Series 10, along with the SIE and the Series 7, expect you to know the $10,000 daily threshold, the difference between a CTR and a SAR, and why structuring is prohibited.