Time to update your CTR Reporting Procedures

February 12, 2020 at 9:11 am Leave a comment

Ok, so it’s not the most exciting topic in the world, but there are few BSA requirements as fundamental as filing transaction reports for currency transfers (CTRs) in excess of $10,000. On February 10th the Financial Crimes Enforcement Network (FinCEN) issued an administrative ruling updating CTR procedures when filing CTRs involving DBAs and Sole Proprietorships. The issue is trickier than it might seem at first because a sole proprietorship is a single person operating as a separate legal entity but in a personal capacity. This ruling is intended to codify precisely who the legal entity is for purposes of filing the CTR. The ruling also addresses similar concerns regarding businesses operating under a “doing business as” designation.

By the way, every time I deal with CTRs I’m reminded of just how antiquated this requirement is. Since everyone knows a financial institution has to report these cash transactions, then how useful is this requirement in terms of catching the bad guys? Everyone agrees that it’s time to update the reporting threshold, but unfortunately the threshold is embedded in statute. Perhaps this is smoothening we can talk about when we go to meet with our Congressional Representatives in a week and a half.

Again, I know this is not the most exciting issue in the world but on a practical level, it would be a big help for financial institutions big and small.

Entry filed under: Compliance, Regulatory. Tags: , , , , , , .

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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