CTR: Currency Transaction Report

A Currency Transaction Report (CTR) is a mandatory FinCEN filing for cash transactions exceeding $10,000 in a single business day.

Key Characteristics

Threshold: >$10,000 cash

Timing: Single business day

Trigger: Automatic—not based on suspicion

Aggregation: Multiple transactions by same person are aggregated

CTR vs. SAR

Routine reporting: Suspicious activity reporting

Threshold-based: Judgment-based

Cash transactions only: Any transaction type

Always required when threshold met: Required when suspicion exists

Structuring

Structuring—breaking transactions into smaller amounts to avoid CTR thresholds—is itself a federal crime, even if the underlying funds are legitimate.

Example: Depositing $9,500 on three consecutive days to avoid a $10,000+ CTR.

CTRs and KYB

For KYB, CTR considerations include:

• Cash-intensive businesses (MSBs, casinos, retail) generate more CTRs
• High CTR volume may indicate higher AML risk
• Understanding expected CTR activity helps calibrate ongoing monitoring

CTRs are filed electronically through FinCEN's BSA E-Filing system within 15 days.

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Related: FinCEN | BSA | SAR