CTR Basics
This report must be filed when cash transactions exceed $10,000 in one business day.
What is a Currency Transaction Report (CTR)
Wendy deposits $6000 in the morning and $6000 later the same day. Must a CTR be filed.
What is yes, total = $12,000 in?
Splitting transactions into smaller amounts to avoid the $10,000 limit is called this?
What is structuring?
Banks, government agencies, and publicly traded companies qualify for these.
What are CTR Exemptions?
CTR records must be retained for this many years.
What is 5 years?
CTRs must be filed within this number of calendar days.
What is 15 calendar days.
Wendy withdraws $7,000 in the morning and $8,000 later that day. Must a CTR be filed?
What is yes, total =$15,000 cash out?
True or False: Structuring is legal if under $10,000.
What is false?
To exempt a customer, the CU must file this report.
What is a DOEP (Designation of Exempt Person)?
CTR filings must include this account detail.
What is the account number?
To require a CTR, transactions must be either this type of cash movement.
What is cash-in-cash-out?
Wendy deposits $12,000 in the morning and withdraws $8,000 later the same day. CTR?
What is yes, deposits and withdrawals are not offset?
Structuring may trigger this type of report instead of a CTR.
What is a Suspicious Activity Report (SAR).
A subsidiary must have at least this percentage ownership by a publicly traded company to qualify for exemption.
What is 51%?
Failing to file a CTR can result in these two types of penalties.
What are civil and criminal penalties?
What is FinCEN (Financial Crimes Enforcement Network)
Wendy withdraws $6,000 and later deposits $8,000 the same day. CTR?
A customer making $9,000 deposits across three days likely doing this.
What is structuring?
Payroll customers must have had an account for at least this long.
What is 12 months?
Multiple transactions in one busines day are treated this way.
What is aggregated together?
Section 1010.312 requires collecting these three key details from the person conducting the transaction.
What are name, address, account number, and ID information.
Andy deposits $6,000 into Zach's account and Barbara deposits $7,000 into the same account that day. CTR?
What is yes, because both acted on behalf of Zach ($12,000 total)?
Name two types of transactions that require CTR reporting.
What are deposits, withdrawals, exchanges/currency, payments, or transfers?
"Frequently" means this many or more reportable transactions in a calendar year.
What is 5?
Name the five pillars of Bank Secrecy Act Compliance Program.
What are the Compliance Officer, Independent Testing, Policies & Controls, Training, and Customer Due Diligence.