CTR Rules: What a Currency Transaction Report Covers

A currency transaction report is a Bank Secrecy Act filing that goes to FinCEN. What counts as currency, how the $10,000 line works, and when the report goes to FinCEN.

Published	14 October 2026

Some cash transactions at a bank lead to a report. That report goes to FinCEN. That form is the currency transaction report, or CTR. It is one of the duties in the bank secrecy act rulebook.

What a currency transaction report is

A currency transaction report is a form financial institutions file with FinCEN. The Bank Secrecy Act requires it. It records a large cash transaction. It does not say anyone did anything wrong. It only says cash moved, and the law wanted a record of it.

FinCEN collects these reports under its FinCEN reporting requirements.

What counts as a transaction in currency

The rule is narrower than people expect. § 1010.100 says a transaction in currency means a transaction involving the physical transfer of currency from one person to another. Cash passing hands. That is the test.

A check is not currency for this purpose. § 1010.100 says a transfer of funds by bank check, bank draft, wire transfer, or other written order is not a transaction in currency. A million-dollar wire triggers no CTR on its own.

The word currency sits inside a broader term the rules use elsewhere. § 1010.100 says monetary instruments include currency and traveler's checks in any form.

The $10,000 threshold and aggregation

FinCEN's alert says a currency transaction report covers a currency transaction of more than $10,000. One deposit of eleven thousand in cash meets it in a single stroke.

Smaller amounts can reach the same line. FinCEN's alert says multiple transactions may be added together to decide whether the reporting threshold has been met. FinCEN's advisory says a currency transaction report covers a transaction in currency of more than $10,000 in aggregate per business day.

Timing has its own rule. § 1010.313 says deposits made at night or over a weekend or holiday are treated as if received on the next business day. A weekend deposit counts toward the next business day.

The aggregation also runs across the whole bank. § 1010.313 says a financial institution includes all of its domestic branch offices for currency transaction reporting. The FFIEC manual says a bank includes all of its domestic branch offices, so branch office transactions must be aggregated. Cash handled at different branches of the same bank counts toward the bank's aggregation.

Who counts as one person

Two shops, one owner. Does the bank add their cash together? Not automatically. The FFIEC manual says a bank must not automatically combine the currency transactions of separately incorporated businesses just because one person owns them all.

The bank has to look closer. The FFIEC manual says the bank itself must decide, using information from the ordinary course of business, whether commonly owned businesses truly operate independently. The FFIEC manual says that if the bank finds the businesses are independent, their common ownership does not require combining their separate transactions.

But the finding cuts both ways. The FFIEC manual says that once a bank finds commonly owned businesses are not independent, it should combine their transactions going forward.

How a CTR is filed

The FFIEC manual says all CTRs must be filed through FinCEN's BSA E-Filing System. The FFIEC manual says forms for reporting currency transactions may be obtained from the BSA E-Filing System.

Blank fields stop the filing. The FFIEC manual says the BSA E-Filing System does not accept CTR filings in which fields marked as critical are left blank. The FFIEC manual also says FinCEN expects banks to give the most complete filing information available. That holds even when a field is not critical.

The system talks back. The FFIEC manual says FinCEN's BSA E-Filing System allows for tracking of filings and sends users acknowledgement notifications and other correspondence. Filings can have errors. The FFIEC manual says a bank that gets FinCEN mail about data quality errors should follow the steps FinCEN sets out.

Filing deadline and record retention

The clock starts on the day of the transaction. The FFIEC manual says a completed CTR must be electronically filed with FinCEN within 15 calendar days after the date of the transaction.

Then the copy goes in the file. The FFIEC manual says the bank must retain copies of CTRs for five years from the date of the report.

Exemptions in brief

Some customers can be exempted. FinCEN's alert says banks file a report to exempt certain customers from currency transaction reporting requirements. The exemption process has its own rules, and this page only names it.

CTR versus suspicious activity report

The CTR and the SAR answer different questions. A CTR says a big cash transaction happened. A suspicious activity report says something looked wrong.

Internal controls for CTR compliance

The rulebook expects the bank to check itself. The FFIEC manual says bank internal controls for reporting currency transactions should assure ongoing compliance with CTR requirements.

One control deserves its own line. The FFIEC manual says internal controls may include senior management approval for staff actions that override currency aggregation systems. A system that adds up the day's cash is only as good as the discipline around anyone who switches it off.

Structuring: the offence the rule names

The rules also name an offence aimed at the CTR. The rule names that attempt directly. § 1010.314 says no person may cause a domestic financial institution to fail to file a required currency transaction report to evade reporting rules. § 1010.314 says no person may cause a domestic financial institution to file a currency report with a material omission or misstatement of fact.

§ 1010.314 is the rule on structured transactions. The bank's part is what this page has said all along. Add up the day's cash across branches. File the report the totals require. Keep the copy.

For more detail, see currency transaction report requirements.