Currency Transaction Reports (CTRs): Filing Rules, Thresholds, and Exemptions

5/4/2026

The Currency Transaction Report is the most mechanical filing in the BSA regime and, for that reason, the one institutions most often get quietly wrong. There is no judgment call about suspicion and no narrative to write — which means errors are almost always about aggregation, party identification, or exemptions that were never maintained.

This guide covers the filing rules precisely, then spends real time on exemptions, because that is where most institutions leave money and staff hours on the table.

The Basic Requirement

A CTR is required for each transaction in currency of more than $10,000 conducted by, through, or to the financial institution in one business day, by or on behalf of the same person.

Three parts of that sentence do the work:

"In currency." Physical cash — U.S. or foreign banknotes and coin. A $50,000 wire transfer is not a CTR. A $50,000 cashier's check purchased with a check drawn on the same bank is not a CTR. Only currency counts.

"More than $10,000." Strictly more. A transaction of exactly $10,000.00 does not require a CTR. One cent more does.

"In one business day, by or on behalf of the same person." This is the aggregation rule, and it is where errors live.

Filing is on FinCEN Form 112 through the BSA E-Filing System, due within 15 days of the transaction.

Aggregation

Multiple currency transactions must be aggregated and treated as a single transaction when the institution has knowledge that they are by or on behalf of the same person and total more than $10,000 in one business day.

What this means in practice:

• Deposits and withdrawals aggregate separately. A customer who deposits $7,000 cash and withdraws $6,000 cash in the same day has not triggered a CTR on either side. Cash in and cash out are not netted, and they are not combined.
• Branches aggregate. Transactions across multiple branches of the same institution on the same business day aggregate. Institutions relying on branch-level review rather than system-level aggregation will miss these.
• Accounts aggregate by person, not by account. A customer depositing $6,000 into a personal account and $6,000 into a business account they control, on the same day, generally aggregates.
• Business day, not calendar day. Your institution's defined business day governs, including how night-deposit and after-hours transactions are dated.

Automated aggregation is standard in core systems, but institutions should verify what their system actually aggregates. Cross-branch, cross-account, and cross-channel aggregation are configuration choices, and defaults are not always correct.

Identifying the Parties

A CTR captures two categories of party, and conflating them is the most common data-quality error.

The person conducting the transaction — whoever physically presents it at the counter.

The person on whose behalf it is conducted — the beneficial party, which may be someone else entirely.

Scenarios that recur:

• An employee deposits $15,000 cash for their employer. The employee is the conductor; the business is the person on whose behalf. Both are reported, in their respective sections.
• A customer deposits $15,000 cash into their own account. The same person occupies both roles, and the form provides for this.
• An armored carrier delivers a business's deposit. Report the business as the party on whose behalf, and follow the specific guidance applicable to common carriers for the conductor.
• A customer deposits $15,000 into a third party's account with no relationship of agency. Both the conductor and the accountholder are reported.

For each party, the institution must obtain and record identifying information — name, address, identification number, and for individuals date of birth and a description of the identification document verified.

For non-customers, this means examining acceptable identification at the counter. A non-customer who refuses to provide identification for a reportable currency transaction should not have the transaction completed, and the refusal itself should be escalated for suspicious activity review.

Structuring

Structuring is breaking a transaction into smaller amounts, or otherwise arranging transactions, for the purpose of evading the reporting requirement. It has been a federal crime since the Money Laundering Control Act of 1986, and it is a crime regardless of whether the underlying funds are legitimate.

Two rules for staff, and both should be trained until reflexive:

Never advise a customer how to avoid a CTR. Telling a customer that transactions over $10,000 are reported is permissible — the requirement is public. Telling them they could deposit $9,000 today and $9,000 tomorrow is assisting a federal crime.

Never refuse to complete a legitimate transaction to avoid filing. Process the transaction as presented, file the CTR, and escalate any suspicion separately.

Common structuring indicators include a customer who asks about the reporting threshold and then reduces the transaction amount, repeated transactions just under $10,000, the same customer transacting at multiple branches on the same day, and multiple individuals making similar sub-threshold deposits into a single account.

Structuring is reported on a SAR, not on a CTR. The two filings are independent — if the transactions that were structured individually exceed the threshold in aggregate, a CTR is also required.

Exemptions

Exemptions are the most underused part of the CTR regime. An institution serving several high-volume cash businesses can eliminate a substantial share of its filings by designating them properly.

Phase I

Phase I exemptions cover:

• Other banks in the United States
• Federal, state, and local government agencies and departments
• Entities exercising governmental authority
• Listed public companies whose securities trade on a covered exchange
• Subsidiaries of listed companies meeting the ownership requirement

Phase I exemptions generally require a one-time designation filing, and the institution must review eligibility annually — a listed company that delists is no longer eligible, and the exemption does not lapse on its own.

Phase II

Phase II exemptions cover two categories:

Non-listed businesses — commercial enterprises that maintain a transaction account at the institution, have been a customer for the required period, frequently engage in reportable currency transactions, and are incorporated or organized in the United States. Certain business types are ineligible, including those primarily engaged in activities such as serving as financial institutions, tax preparation, gaming, and several others specified in the regulation.

Payroll customers — businesses that regularly withdraw more than $10,000 in currency to pay U.S. employees, subject to comparable conditions.

Phase II exemptions require a designation filing on FinCEN Form 110, and they carry an annual review obligation: the institution must confirm continued eligibility and document the review.

Why exemptions get institutions in trouble

Almost never because the wrong customer was exempted. Almost always because the annual review was not performed. An exemption that has not been reviewed is an unsupported exemption, and every CTR not filed during that period becomes a potential violation.

The practical control is calendaring reviews at designation time and assigning a named owner, rather than relying on an annual sweep that competes with year-end work.

Recordkeeping

Retain CTRs and supporting records for five years from the filing date. Retain exemption designations and annual review documentation for the same period.

Note that CTRs, unlike SARs, are not confidential from the customer. An institution may tell a customer that a CTR was filed, and many do as a matter of routine service. What remains prohibited is helping the customer avoid one.

Quality Control

Institutions with clean CTR examination results generally run three controls:

1. Daily aggregation review. A report of currency activity approaching the threshold, reviewed by someone other than the teller, to catch aggregation the system missed.
2. Pre-filing data check. Verification that party information is complete and that conductor versus beneficial party is assigned correctly, before submission rather than after.
3. Filing confirmation reconciliation. A monthly tie-out of transactions requiring a CTR to CTRs accepted by the E-Filing System, which catches both missed filings and filings that errored on submission.

The third control is the one most often absent, and it is the one that catches the failure mode nobody notices: a CTR that was prepared, submitted, rejected for a data error, and never resubmitted.

Institutions building depth here should look at structured BSA training that covers currency reporting alongside the rest of the program, since CTR errors and SAR errors usually share a root cause in front-line training.

Training the Front Line

CTR accuracy is decided at the counter, not in the back office. By the time a filing reaches the BSA analyst, the party information has already been captured or missed, and the customer has already been served or alerted. That makes teller training the highest-leverage control in the whole currency reporting process.

Effective front-line training covers four things concretely rather than abstractly.

The mechanics of who to record. Staff should be able to answer, without hesitation, who the conductor is and who the transaction is on behalf of in the four or five scenarios that actually occur at that institution — an employee depositing for a business, a spouse depositing to a joint account, an armored carrier delivery, a non-customer cashing an on-us check. Abstract explanations of the two roles do not survive contact with a queue of customers.

What identification to obtain, and when. Particularly for non-customers, where staff are least practiced and most likely to complete a transaction without the required information because the customer is impatient.

The scripting for threshold questions. Every teller will eventually be asked whether a transaction gets reported. They need a sentence they can say — the requirement is public and can be stated plainly — and a clear rule that any conversation about reducing the amount ends the discussion and starts an escalation.

Why aggregation exists. Staff who understand that transactions combine across branches and accounts spot the customer making a second deposit across town in a way that a rules-based explanation never produces.

The measurement that tells you whether training worked is not a quiz score. It is the error rate on filed CTRs — missing identification fields, wrong party assignment, incomplete addresses — tracked by branch and reviewed with supervisors. Institutions that report this metric back to branches see error rates fall; institutions that correct the data centrally and say nothing see the same errors indefinitely, because the person creating them never learns.

Frequently Asked Questions

What is the CTR threshold?

More than $10,000 in currency, by or on behalf of the same person, in one business day. A transaction of exactly $10,000 does not require a report; $10,000.01 does. Multiple transactions aggregate when the institution knows they are by or on behalf of the same person.

Do cash deposits and withdrawals get added together for a CTR?

No. Cash in and cash out are evaluated separately and are not netted or combined. A customer who deposits $7,000 in currency and withdraws $6,000 in currency on the same day has not triggered a CTR on either side, though the pattern may warrant a suspicious activity review.

When is a CTR due?

Within 15 days of the transaction, filed electronically with FinCEN on Form 112 through the BSA E-Filing System. Records must be retained for five years from the filing date.

Can I tell a customer that a CTR was filed?

Yes. Unlike SARs, CTRs are not confidential from the customer, and staff may explain that currency transactions over $10,000 are reported. What is prohibited is advising a customer how to structure transactions to avoid the report, which is assisting a federal crime.

What is the difference between a Phase I and a Phase II exemption?

Phase I covers other banks, government entities, listed public companies, and qualifying subsidiaries. Phase II covers eligible non-listed businesses and payroll customers that frequently conduct large currency transactions. Both require designation and annual eligibility review; Phase II has additional eligibility conditions and excludes certain business types.

What happens if we miss a required CTR?

File it late rather than not at all, and document the cause. Isolated late filings are typically handled as a correctable deficiency; systemic failures — particularly aggregation logic that never worked, or exemptions maintained without annual review — are treated as program deficiencies and can support civil money penalties.