Guidance on the New Currency Transaction Report (CTR)
As you were advised earlier this year, the U.S. Treasury has revised its Currency
Transaction Report (CTR) form that banks and other institutions file regarding
large-dollar transactions (see FIL-38-95: Inactive Financial Institution Letters: dated May 30, 1995). The information requested
on this form assists the government in criminal investigations and other matters. Attached
for your information is new guidance from the Treasury Department's Financial Crimes
Enforcement Network (FinCEN) about completing and filing the revised CTR. This latest
guidance is intended to answer general, basic questions; it is not meant to be
comprehensive and does not replace the CTR form instructions and/or the regulations.
Please note that although the new CTR became effective October 1, 1995, FinCEN is
allowing a transition period until December 31, 1995 (see page 3 of the attachment) before
the new form must be used. Between October 1 and December 31, 1995, institutions will not
be penalized for continuing to file the old CTR or photocopies of the "advance
copy" of the new CTR that has been made available for training purposes since May of
1995, provided they have made a "good faith" effort to obtain and use the new
form as soon as possible after October 1, 1995. This same policy also applies to
institutions that file CTRs by magnetic media, such as a diskette or tape.
Also, please note that the box indicating "Suspicious Transaction" has been
eliminated from the new CTR form (also on page 3 of the attachment). This is because,
starting October 1, 1995, only suspicious transactions larger than $10,000 should continue
to be reported on the CTR (in addition to being noted in a criminal referral form).
Suspicious transactions of $10,000 or less will be reported only on the criminal referral
form. Banks should continue to use the FDIC's criminal referral forms (Report of Apparent
Crime, Forms 6710/06 and 6710/06A) until the new, interagency Suspicious Activity Report
(SAR) is released later this year (see FIL-69-95: Inactive Financial Institution Letters: dated October 10, 1995).
The new CTR forms may be obtained by calling the IRS Forms Distribution Center at
800-829-3676. Simply follow the voice prompts, press Option #1 (for ordering blank forms)
and make your request by form number (IRS Form 4789). Information on magnetic filing
specifications may be obtained by writing to: IRS Detroit Computing Center, ATTN: CTR
Magnetic Media Coordinator, P. O. Box 33604, Detroit, MI 48232-5604.
Additional copies of the attached FinCEN publication may be obtained by calling FinCEN
at 800-949-2732, or by computer and modem hook-up to the Treasury's Bank Secrecy Act
Bulletin Board (dial 313-234-1453).
Questions concerning the new CTR form should be directed to FinCEN at 1-800-949-2732.