A Currency Transaction Report (CTR) must be filed for each transaction in currency of more than $10,000 conducted by, through, or to a financial institution on a single business day. Multiple currency transactions must be aggregated and treated as one when they total more than $10,000 and are by or on behalf of the same person. The CTR is filed electronically with FinCEN within 15 calendar days of the transaction. Unlike a SAR, a CTR is not based on suspicion; it is a flat reporting requirement triggered by the dollar amount.
Key Takeaways:
- A CTR is required for currency transactions of more than $10,000 in a single business day, by or on behalf of the same person
- Transactions are aggregated: two or more cash transactions totaling more than $10,000 on the same business day count as one reportable event
- The filing deadline is 15 calendar days from the transaction date
- Deliberately structuring transactions to stay under $10,000 is a separate federal crime and a SAR trigger
- CTR rules and aggregation are set by 31 CFR § 1010.311 and related sections
What Triggers a CTR
The trigger is mechanical, not judgmental. A bank must file a CTR when currency (physical coin and paper money) of more than $10,000 is involved in a transaction or aggregated transactions on a single business day. "More than $10,000" means exactly that: $10,000.00 even does not trigger a CTR; $10,000.01 does.
Reportable transactions include cash deposits, cash withdrawals, currency exchanges, and cash used to purchase monetary instruments or make payments, when they exceed the threshold. The CTR captures identifying information about the person conducting the transaction, the person on whose behalf it was conducted, and the transaction itself.
Because the CTR is not suspicion-based, you file it even when the customer is entirely legitimate and the activity is routine. A business that deposits $15,000 in cash daily generates a CTR each day, regardless of how well you know them, unless an exemption applies.
The Aggregation Rule
Aggregation is where banks most often make errors. The rule: multiple currency transactions are treated as a single transaction if the bank has knowledge that they are by or on behalf of the same person and they total more than $10,000 during any one business day.
In practice this means:
- Two cash deposits of $6,000 each by the same customer on the same business day aggregate to $12,000 and require a CTR
- A cash deposit and a cash withdrawal generally do not net against each other; cash in and cash out are evaluated separately
- Transactions across multiple branches by the same person on the same day must be aggregated when the bank has the knowledge to do so
- Transactions on behalf of the same person through different individuals aggregate when the beneficial party is the same
Your systems need to aggregate by customer across the business day, not just flag single transactions over the threshold. A bank that only catches individual large transactions, and misses two smaller ones that sum to more than $10,000, has a reporting gap examiners look for. This connects to the monitoring discipline in our BSA/AML requirements for community banks.
The 15-Day Filing Deadline
A CTR must be filed electronically through the BSA E-Filing System within 15 calendar days following the day of the transaction. For transactions where the bank must obtain additional information, the deadline still runs from the transaction date.
Records relating to the CTR, including the report itself and supporting identification, must be retained for five years. Late or missed CTR filings are BSA violations, and patterns of CTR errors, incomplete reports, missed deadlines, or aggregation failures, are common examination findings.
CTR Exemptions
Banks can exempt certain customers from CTR filing to reduce the volume of routine reports, but the exemption rules are specific and must be followed precisely.
There are two phases of exempt persons:
- Phase I: Includes other banks, government agencies, and entities whose stock is listed on a major U.S. exchange (and certain subsidiaries). These generally do not require an annual renewal in the same way.
- Phase II: Includes certain "non-listed businesses" and "payroll customers" that meet defined criteria, such as maintaining an account for a required period and conducting frequent reportable currency transactions.
To use an exemption, the bank must designate the exempt person by filing a Designation of Exempt Person (DOEP) form and must conduct ongoing review to confirm continued eligibility. An incorrectly applied exemption, or a failure to monitor an exempt customer, is itself a finding. Exemptions reduce paperwork but increase oversight responsibility, so many institutions use them selectively.
CTRs, Structuring, and SARs
CTRs and SARs intersect around structuring. Structuring is breaking up cash transactions to keep each one under the $10,000 reporting threshold and evade the CTR requirement. It is a federal crime under 31 USC § 5324, and a bank that detects apparent structuring must file a SAR, even though no CTR was triggered.
A few practical points:
- A customer asking how to avoid a CTR, or splitting a $12,000 deposit into two sub-$10,000 deposits, is a classic structuring red flag and a SAR consideration
- Telling a customer about the CTR threshold to help them avoid it can implicate the bank
- The CTR and SAR systems work together: CTRs capture the large legitimate flows, SARs capture the attempts to evade them
For the SAR side of this relationship, see our guide on SAR filing requirements and deadlines. Both are tested together in a BSA/AML exam.
CTR compliance is an aggregation-and-deadline problem: catch same-day same-person cash across the institution and file within 15 days. See how Canarie tracks BSA reporting obligations and evidence →
Frequently Asked Questions
What is the CTR filing threshold?
A CTR is required for currency transactions of more than $10,000 conducted by, through, or to a bank on a single business day. The threshold is "more than" $10,000, so exactly $10,000.00 does not trigger a CTR, but any amount above it does. Multiple same-day transactions by the same person aggregate toward the threshold.
How long do you have to file a CTR?
A CTR must be filed electronically with FinCEN within 15 calendar days following the day of the transaction. Records related to the CTR must be retained for five years. Missing the 15-day deadline is a BSA violation.
How does CTR aggregation work?
Multiple currency transactions by or on behalf of the same person on the same business day are aggregated and treated as one transaction when they total more than $10,000. This includes transactions across different branches when the bank has the knowledge to link them. Systems must aggregate by customer per business day, not just flag single large transactions.
What is the difference between a CTR and a SAR?
A CTR is a flat, non-suspicion reporting requirement triggered by currency transactions over $10,000. A SAR is filed when activity is suspicious, regardless of amount above the applicable threshold. Structuring transactions to avoid a CTR is itself suspicious and requires a SAR.
Can a bank exempt customers from CTR filing?
Yes. Banks can designate eligible Phase I and Phase II exempt persons by filing a Designation of Exempt Person form, which removes the need to file routine CTRs for those customers. Exemptions require ongoing eligibility review, and misapplied or unmonitored exemptions are examination findings.
Make CTR Aggregation Automatic
The two failure points in CTR compliance are aggregation, catching same-day same-person cash across branches, and the 15-day deadline. Both are systematic problems that manual processes miss, especially at volume.
Canarie maps your BSA reporting obligations to monitored workflows, tracks filing deadlines, and preserves the evidence that shows examiners your CTR and SAR processes are working together.