Currency Transaction Report (CTR)

With Suspicious Activity Reports (SARs) covering suspicious activity, let's look at the other major reporting requirement: the Currency Transaction Report, which applies to all large cash transactions regardless of whether they seem suspicious.

What Is a CTR?

• A Currency Transaction Report (CTR) must be filed for cash transactions exceeding $10,000 in a single business day
• Filed with the Financial Crimes Enforcement Network (FinCEN) within 15 calendar days of the transaction
• Unlike a SAR, a CTR does not require suspicion; it is a mandatory, automatic filing for all qualifying cash transactions
• Applies to deposits, withdrawals, exchanges of currency, or other payments and transfers involving cash

Think of it this way: A CTR works like a speed camera on a highway. It does not matter why you are driving fast or whether you have good intentions. If you go over the limit, the camera fires automatically. Similarly, any cash transaction over $10,000 triggers a CTR filing regardless of the circumstances.

Key CTR Rules

• The $10,000 threshold applies to a single business day, not a single transaction
• Multiple transactions that total over $10,000 must also be reported if the firm knows they are by or on behalf of the same person
• Cash in and cash out are totaled separately, not combined. A same-day $8,000 cash deposit and a $4,000 cash withdrawal are not added together to reach $12,000; the $8,000 cash-in total and the $4,000 cash-out total are each measured against the $10,000 threshold on their own
• The customer may be aware that a CTR is being filed (unlike a SAR, there is no tipping-off prohibition for CTRs)
• Records must be retained for five years from the date of the report

SAR vs. CTR Comparison

This is a high-frequency exam topic. Know the differences cold:

Exam Tip: Gotchas

• The SAR threshold ($5,000) and CTR threshold ($10,000) are different numbers. The exam loves to test whether you can keep them straight. SARs require suspicion; CTRs are automatic for any cash transaction over $10,000.
• Three-deadline reference: CTR = 15 calendar days, SAR = 30 calendar days (60 if no suspect is identified), OFAC blocked transaction report = 10 business days. The OFAC deadline uses business days; CTR and SAR use calendar days.

Structuring (Smurfing)

• Structuring is the deliberate breaking up of cash transactions to avoid the $10,000 CTR reporting threshold
• Also called "smurfing" because it often involves using multiple people ("smurfs") to make smaller deposits
• Structuring is illegal even if the underlying funds are legitimate
• If a firm detects structuring, it must file a SAR (not just a CTR)
• Example: A customer deposits $9,500 in cash on Monday, then $9,500 on Tuesday, specifically to avoid the $10,000 threshold

Exam Tip: Gotchas

Structuring itself is a crime; the customer does not need to be laundering money for structuring to be illegal. Breaking up deposits to avoid the $10,000 reporting threshold violates the law regardless of where the money came from. The firm must report structuring via a SAR.

Memory Aid: CTR = Cash over $10,000 (automatic). SAR = Suspicious over $5,000 (requires suspicion).

What Should You Check on Exam Day?

• Can you state the CTR threshold and filing deadline?
• Do you know that cash in and cash out are totaled separately, not combined, when checking the $10,000 threshold?
• Can you explain why a CTR does not require suspicion, unlike a SAR?
• Do you know what structuring is and why it's illegal even with legitimate funds?
• Can you compare the SAR and CTR thresholds, deadlines, and notification rules?