The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) updated its Currency Transaction Report (CTR) Electronic Filing Requirements document in October 2019 and again modified these details in November 2019. A quick summary of the latest changes and text from applicable sections of the CTR filing guide and FAQs, which were updated to clarify a change in the use of the ‘Multiple transactions’ check box on the CTR form follows.

• If you are reporting on multiple cash-ins totaling more than $10,000 or multiple cash-outs totaling more than $10,000, check ‘Item 3 Multiple transactions’
• Do not combine cash-ins and cash-outs
• If an amount is not reportable, do not count it when determining if you have multiple transactions; non-reportable amounts are amounts that, when combined with all other like transactions (cash-ins or cash-outs), do not exceed the $10,000 reporting threshold
• Only check ‘Item 3’ for the person(s) it applies to
• A deposit into multiple accounts should be reported as multiple transactions for the conductor if each transaction is posted individually

‘Item 24 Aggregated transactions’ occur in specific situations and are determined separately from multiple transactions. Refer to FAQ #27 for details and examples on when to use ‘Aggregated Transactions.’

FinCEN CTR Electronic Filing Requirements XML Schema 2.0 User Guide: Attachment C – Electronic Filing Instructions (Page 97)

‘Item 3 Multiple transactions’ – Check ‘Item 3’ if multiple cash transactions of any amount totaling more than $10,000 as cash-in or more than $10,000 as cash-out (cash-in/out transactions should not be combined) were conducted in a single business day by or for the person recorded in Part I. For example, if a customer makes a $12,000 deposit and a $300 deposit on the same day, ‘Item 3’ should be checked. However, if a customer makes a $12,000 deposit and a $300 withdrawal, ‘Item 3’ should not be checked. ‘Item 3 Multiple transactions’ is related to, but not the same as, ‘Item 24 Aggregated transactions.’ Whereas ‘Item 3’ should be checked each time multiple transactions are reported as a single transaction, ‘Item 24 Aggregated transaction’ should only be checked when all the specific conditions underlying that option have been satisfied.

Frequently Asked Questions Regarding the FinCEN Currency Transaction Report (CTR): Question #18

Filers should check ‘Item 3 Multiple transactions’ if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I. ‘Multiple transactions’ is not the same as the Item 24 Aggregated transactions,’ which only involves multiple transactions; all of which are below the reporting requirements and requires at least one of the transactions to be a teller transaction. The use of ‘Item 24 Aggregated transactions’ is discussed in more detail in FAQ #27. For example, if Tom Doe deposited $6,000 to his personal account in the morning and then later in the same business day deposited an additional $5,000 to his personal account, the filing institution would check ‘Item 3 Multiple transactions’ when completing a Part I on Tom Doe. Another example would be if Tom Doe deposited $7,000 into ABC Restaurant’s business account and then later in the same business day, Jane Smith deposited $5,000 into ABC Restaurant’s business account; the filing institution would check ‘Item 3 Multiple transactions’ when completing a Part I on ABC Restaurant. However, the filing institution would NOT check ‘Item 3 Multiple transactions’ when completing a Part I on Tom Doe or Jane Smith.

There may be instances where, at one time, an individual brings in funds to deposit to multiple accounts at a financial institution. Whether or not to check ‘Item 3 Multiple transactions’ in these instances depends on the financial institution’s procedures. For example, a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing as a matter of policy, to define each as a separate transaction. When completing Part I on the conductor, the financial institution would check ‘Item 3 Multiple transactions’ as a result of its procedures to post the transactions individually and treat each one as a separate transaction.

Questions? Contact KPM Manager Richard Dugas for additional guidance on this topic.