Currency Transaction Report (CTR)

What is a currency transaction report?

A currency transaction report (CTR) is the report a US financial institution files with FinCEN for each deposit, withdrawal, exchange of currency or other payment or transfer involving more than $10,000 in currency. In banking, CTR means this report, not click-through rate. The requirement comes from the Bank Secrecy Act (BSA) and is set out in 31 CFR 1010.311. FinCEN's CTR guidance refers to the form as FinCEN CTR 112.

When is a CTR required?

The trigger is more than $10,000 in currency, meaning coin and paper money of the United States or another country designated as legal tender (31 CFR 1010.100). Checks, wires and card payments are not currency.

Under 31 CFR 1010.313, multiple currency transactions are treated as one if the bank knows they are made by or for the same person and total more than $10,000 cash in or cash out during one business day. All domestic branches count as one institution, so three $4,000 deposits at three branches on the same day are reportable.

How and when is a CTR filed?

The bank files, not the customer. CTRs go to FinCEN electronically through the BSA E-Filing System within 15 days of the transaction (31 CFR 1010.306). FinCEN's CTR FAQs state this as 15 calendar days. The bank keeps a copy of each report for five years from the date of the report.

Which customers are exempt?

A bank does not file CTRs for transactions with an exempt person under 31 CFR 1020.315. FinCEN guidance commonly splits these into two groups. Phase I covers banks (for domestic operations), government agencies and listed companies with their qualifying subsidiaries. Phase II covers non-listed businesses and payroll customers, which need a transaction account, generally for at least two months, and frequent currency transactions over $10,000.

The bank designates an exempt person with a Designation of Exempt Person (DOEP, FinCEN Form 110) within 30 calendar days after the first reportable transaction, reviews eligibility at least annually and still files SARs where warranted. See FinCEN's exemption guidance.

What is structuring?

Structuring means conducting or attempting currency transactions, in any amount, at one or more institutions to avoid the reporting requirement, such as splitting a $15,000 deposit into smaller amounts (31 CFR 1010.100). It is a federal crime under 31 U.S.C. 5324, with a base penalty of a fine, up to five years in prison, or both.

Structuring is where CTRs and SARs meet. A bank must file a suspicious activity report (SAR) when a transaction involves or aggregates at least $5,000 and the bank knows or suspects it was designed to evade BSA requirements (31 CFR 1020.320).

How does a CTR differ from a SAR?

A CTR is triggered by the amount alone: once cash crosses the threshold, the bank files whatever it thinks of the customer. A SAR turns on suspicion, starts at $5,000 and is due within 30 calendar days of detection, or up to 60 when no suspect is identified.

Where do AI agents help with CTRs?

CTR work is a data problem with a human decision at the end. AI agents can aggregate cash activity across branches, channels and related accounts so same-day totals are not missed. They can flag possible structuring for an investigator alongside transaction monitoring alerts, pre-populate CTR fields from core banking records, and prepare exemption review cases for an analyst.

Zamp builds AI employees for back-office work, with approval gates, Needs Attention routing for exceptions and a full audit trail. In a CTR process, a person approves every filing and every structuring escalation. For program context, see AML automation, what examiners ask about AI in BSA/AML programs and anti-money laundering (AML).

Frequently asked questions

What is the CTR threshold?

More than $10,000 in currency. Exactly $10,000 is below it, but transactions by or for the same person are added together across one business day.

How long does a bank have to file a CTR?

Within 15 days of the transaction, filed through the BSA E-Filing System. FinCEN's FAQs describe this as 15 calendar days.

Is it illegal to deposit just under $10,000 in cash?

Not by itself. Breaking up cash to stay under the threshold is structuring, a crime under 31 U.S.C. 5324, even when the money is lawfully earned.

What is the difference between a CTR and a SAR?

A CTR is filed on the amount of cash. A SAR is filed on suspicion at $5,000 or more. Structuring can lead to both.