By: Nash Cullens
On October 1, 2019, FinCEN issued new guidance to all E-Filers of discrete and XML batch filed Currency Transaction Reports in regard to completing Item 2 (Person involved in transaction) of Part I of the CTR form. Previously, FinCEN stated that if more than one option for Part I Item 2 applied, the bank was to only complete a single Part I (Person involved in transaction) for that person involved in the transaction and to aggregate all transactions conducted by that person in Item 21 (Cash in) or Item 22 (Cash out) of Part I for the transactor.
Due to CTRs being rejected and users of the BSA information not being able to fully understand how the transactions were being conducted, FinCEN has amended how line 2 of the CTR should be submitted. Now, for CTRs in which more than one option applies for Item 2 of Part I, the Bank should complete a separate Part I for each option of Item 2 that applies for the person involved in the transaction.
FinCEN issued this example to help clarify:
For example, if the Part I person makes a $5,000 deposit into their personal account and a separate
$7,000 deposit into the account of another person/entity, there will be one Part I on that person reporting option 2a on the personal deposit with that amount and account number in Item 21 “Cash in amount”. There will be a second Part I on that person reporting option 2b on the person/entity account transaction with that amount and account number in Item 21.
The effective date for this amendment has been extended from February 1, 2020, to September 1, 2020.
For the full article published by FinCEN, please use the following link:
https://bsaefiling.fincen.treas.gov/docs/FinCENNoticetoE-FilersRegardingCTRMultipleTransactionsEffectiveDate.pdf
For further clarification and examples, please use the following link and click FAQ #16:
https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
Additionally, on November 22, 2019, FinCEN amended a recent statement released on October 1, 2019, in regard to indicating multiple transactions and aggregated transactions on Currency Transaction Reports. Previously, FinCEN stated that if a reportable transaction occurs such as a deposit, and a non-reportable transaction occurs such as a withdrawal under the $10,000 threshold, the Bank should indicate on Part I Item 3 (multiple transactions) that multiple transactions occurred. FinCEN amended this stating that multiple transactions should only be indicated if the multiple transactions that occurred are included in the CTR reportable amount. For instance, if multiple deposits occurred totaling over $10,000 dollars, multiple transactions should be indicated. However, if one deposit over $10,000 occurred as well as a withdrawal under $10,000, multiple transactions should not be indicated.
FinCEN released the following example to help clarify:
Item 3 Multiple transactions: Check Item 3 if multiple cash transactions of any
amount totaling more than $10,000 as cash in or more than $10,000 as cash out
(cash in and cash out transactions should not be combined) were conducted in a
single business day by or for the person recorded in Part I. For example, if a
customer makes a $12,000 deposit and a $300 deposit on the same day, item 3
should be checked. However, if a customer makes a $12,000 deposit and a $300
withdrawal, item 3 should not be checked.
Additionally, FinCEN further clarified that even though Item 3 of Part I (Multiple Transactions) and Item 24 of Part II (Aggregated Transactions) can be related, aggregated transactions should only be indicated if all the underlying requirements are satisfied.
For the full article published by FinCEN, please use the following link:
https://bsaefiling.fincen.treas.gov/docs/FinCENNoticetoE-FilersRegardingCTRMultipleTransactionsInstructions.pdf
On October 1, 2019, FinCEN issued new guidance to all E-Filers of discrete and XML batch filed Currency Transaction Reports in regard to completing Item 2 (Person involved in transaction) of Part I of the CTR form. Previously, FinCEN stated that if more than one option for Part I Item 2 applied, the bank was to only complete a single Part I (Person involved in transaction) for that person involved in the transaction and to aggregate all transactions conducted by that person in Item 21 (Cash in) or Item 22 (Cash out) of Part I for the transactor.
Due to CTRs being rejected and users of the BSA information not being able to fully understand how the transactions were being conducted, FinCEN has amended how line 2 of the CTR should be submitted. Now, for CTRs in which more than one option applies for Item 2 of Part I, the Bank should complete a separate Part I for each option of Item 2 that applies for the person involved in the transaction.
FinCEN issued this example to help clarify:
For example, if the Part I person makes a $5,000 deposit into their personal account and a separate
$7,000 deposit into the account of another person/entity, there will be one Part I on that person reporting option 2a on the personal deposit with that amount and account number in Item 21 “Cash in amount”. There will be a second Part I on that person reporting option 2b on the person/entity account transaction with that amount and account number in Item 21.
The effective date for this amendment has been extended from February 1, 2020, to September 1, 2020.
For the full article published by FinCEN, please use the following link:
https://bsaefiling.fincen.treas.gov/docs/FinCENNoticetoE-FilersRegardingCTRMultipleTransactionsEffectiveDate.pdf
For further clarification and examples, please use the following link and click FAQ #16:
https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
Additionally, on November 22, 2019, FinCEN amended a recent statement released on October 1, 2019, in regard to indicating multiple transactions and aggregated transactions on Currency Transaction Reports. Previously, FinCEN stated that if a reportable transaction occurs such as a deposit, and a non-reportable transaction occurs such as a withdrawal under the $10,000 threshold, the Bank should indicate on Part I Item 3 (multiple transactions) that multiple transactions occurred. FinCEN amended this stating that multiple transactions should only be indicated if the multiple transactions that occurred are included in the CTR reportable amount. For instance, if multiple deposits occurred totaling over $10,000 dollars, multiple transactions should be indicated. However, if one deposit over $10,000 occurred as well as a withdrawal under $10,000, multiple transactions should not be indicated.
FinCEN released the following example to help clarify:
Item 3 Multiple transactions: Check Item 3 if multiple cash transactions of any
amount totaling more than $10,000 as cash in or more than $10,000 as cash out
(cash in and cash out transactions should not be combined) were conducted in a
single business day by or for the person recorded in Part I. For example, if a
customer makes a $12,000 deposit and a $300 deposit on the same day, item 3
should be checked. However, if a customer makes a $12,000 deposit and a $300
withdrawal, item 3 should not be checked.
Additionally, FinCEN further clarified that even though Item 3 of Part I (Multiple Transactions) and Item 24 of Part II (Aggregated Transactions) can be related, aggregated transactions should only be indicated if all the underlying requirements are satisfied.
For the full article published by FinCEN, please use the following link:
https://bsaefiling.fincen.treas.gov/docs/FinCENNoticetoE-FilersRegardingCTRMultipleTransactionsInstructions.pdf
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