A Currency Transaction Report is filed for covered U.S. currency transactions over USD 10,000, including aggregated cash activity known to involve the same person.
A Currency Transaction Report (CTR) is an electronic Bank Secrecy Act report that a U.S. bank files with FinCEN for a covered transaction in currency of more than USD 10,000 by, through, or to the bank. Multiple cash transactions must be aggregated when the bank knows they are conducted by or on behalf of the same person and total more than USD 10,000 in cash in or cash out during one business day.
Covered activity can include cash deposits, withdrawals, currency exchanges, loan payments made in cash, purchases of monetary instruments with cash, and cash used to fund another payment or transfer.
A check, card payment, ACH entry, or wire transfer is not itself a transaction in currency when no physical currency changes hands. If cash is used to purchase a cashier’s check or fund a wire, the cash portion can still be relevant to currency reporting.
A bank treats multiple transactions as one reportable transaction when:
Aggregation extends across the bank’s domestic branches. Transactions for separately incorporated businesses are not automatically combined solely because the entities share an owner; the bank considers whether the activity is actually on behalf of one person based on facts it knows in the ordinary course of business.
Assume one person deposits USD 6,500 in cash at Branch A for a business account and later deposits USD 5,000 in cash at Branch B for the same business on the same business day.
| Activity | Cash direction | Amount |
|---|---|---|
| Branch A deposit | Cash in | USD 6,500 |
| Branch B deposit | Cash in | USD 5,000 |
| Aggregated cash in | Cash in | USD 11,500 |
Because the bank knows the deposits are on behalf of the same business and aggregated cash in exceeds USD 10,000, the bank generally files a CTR. If the person also withdraws USD 4,000 that day, the withdrawal is cash out and is not subtracted from the USD 11,500 cash-in total.
The report can identify both the person conducting the transaction and the person or entity on whose behalf it was conducted, as applicable.
Banks generally file CTRs electronically within 15 calendar days after the reportable transaction. They verify and record required information about the individual conducting the transaction and the person on whose behalf it is conducted. A bank must retain a record of the CTR for five years from filing.
The CTR form and instructions determine the required fields. A bank can ask questions needed to identify the conductor, beneficiary, transaction, or exemption, but a CTR requirement does not by itself mean the customer must prove the cash is lawful before completing every transaction.
CTR filing is threshold-based. Suspicious activity reporting uses different standards and is not limited to cash over USD 10,000. A bank can file a CTR without a suspicious activity report, file both when separate requirements are met, or review lower-value activity for possible suspicious patterns.
Customers should not divide a cash transaction to avoid a report. Structuring can involve transactions at or below the threshold, at one or more institutions, on one or more days, when the purpose is to evade reporting.
FinCEN rules permit banks to exempt specified categories of persons and qualifying customers from some CTR filings. Exemption status depends on regulatory criteria, documentation, and bank procedures. A business that regularly handles cash is not automatically exempt merely because its large deposits are routine.
This page provides general financial and regulatory education, not legal or compliance advice. Current FinCEN rules, form instructions, exemptions, and transaction facts control a specific filing decision.