The short answer
A Currency Transaction Report is required when cash in or cash out by or on behalf of one person totals more than $10,000 during one business day (exactly $10,000 does not trigger it). The CTR must be e-filed with FinCEN within 15 calendar days following the day of the transaction, and a copy kept for five years.
Currency transactions by or on behalf of the same person. Enter each deposit, withdrawal, exchange, or other cash payment.
When is a CTR required?
Under 31 CFR 1010.311, a financial institution must report each deposit, withdrawal, exchange of currency, or other payment or transfer involving a transaction in currency of more than $10,000. "Currency" means coin and paper money; checks, wires, and monetary instruments purchased with cash are not currency for this rule (the cash used to buy them is). The report is FinCEN Form 112, filed through the BSA E-Filing System.
How many days do you have to file a CTR?
15 calendar days following the day on which the reportable transaction occurred (31 CFR 1010.306(a)(1)). Two details trip institutions up on exam:
- The count is calendar days, not business days. The 25-business-day figure some staff remember applied to paper filing, which FinCEN discontinued in 2012.
- The rule provides no weekend or holiday extension. When day 15 falls on a Saturday, Sunday, or holiday, the conservative practice is to file by the preceding business day.
Keep a copy (or the E-Filing acknowledgment with the BSA identifier) for five years from the filing date (31 CFR 1010.306(a)(2)). Late filings are reportable compliance events; a pattern of them is a classic BSA/AML exam finding.
CTR aggregation rules (31 CFR 1010.313)
Multiple currency transactions are treated as a single transaction when the institution has knowledge they are by or on behalf of the same person and they total more than $10,000 in cash in or cash out during one business day:
- All branches count. A $6,000 deposit at one branch and $5,000 at another the same day aggregate to $11,000 (31 CFR 1010.313(a)).
- Cash in and cash out aggregate separately. They are never netted. An $8,000 deposit and an $8,000 withdrawal require no CTR; a $10,500 deposit alone does. If both sides exceed $10,000, one CTR reports both totals.
- Weekend and night deposits roll forward. Deposits made at night, over a weekend, or on a holiday are treated as received on the next business day, and aggregate with that day's transactions (31 CFR 1010.313(b)).
- "On behalf of" matters. A courier depositing $7,000 to a business account plus the owner depositing $5,000 to the same account is one $12,000 cash-in aggregation once the bank knows both are for the same person.
CTR exemptions at a high level
Banks may exempt Phase I customers (other banks, federal/state/local government entities, and companies listed on major exchanges plus their majority-owned subsidiaries) and Phase II customers (non-listed businesses and payroll customers meeting the eligibility tests in 31 CFR 1020.315) by filing a Designation of Exempt Person (FinCEN Form 110). Phase II exemptions require the customer to have maintained a transaction account for at least two months (or a documented risk-based decision sooner), frequent reportable currency transactions, and annual reviews. Ineligible businesses, such as money services businesses, auto dealers, and law firms, cannot be exempted. Exemption never removes SAR obligations.
Worked example
A restaurant owner deposits $7,000 in cash on Saturday at the night drop and $4,000 in cash on Monday at the teller line. Saturday is not a business day for the bank:
- The Saturday deposit is treated as received on Monday (31 CFR 1010.313(b)), so Monday's cash in totals $11,000.
- $11,000 is more than $10,000: a CTR is required, reporting both transactions.
- The filing deadline is 15 calendar days after Monday. The calculator above shows the exact date and flags it when it lands on a weekend.
For the full filing walkthrough, including who must be identified on the form, see our CTR filing requirements guide and the related SAR filing deadlines.
Conservative assumptions this calculator makes
- All entered transactions are assumed to be by or on behalf of the same person, with the institution's knowledge, so they aggregate. If they are unrelated persons, run them separately.
- Transactions on non-business days are rolled to the next business day for aggregation. The regulation states this for deposits; the calculator applies it to withdrawals too, which can only add reportable days, never remove them.
- The 15-day deadline is never extended for weekends or holidays, and the tool flags deadlines that land on non-business days.
- Business days default to Monday through Friday excluding Federal Reserve holidays, with a Saturday toggle for banks whose offices are open.
Frequently asked questions
A CTR must be filed within how many days?
Within 15 calendar days following the day the reportable transaction occurred (31 CFR 1010.306(a)(1)). CTRs are filed electronically through FinCEN's BSA E-Filing System. The old 25-day allowance applied only to discontinued paper filing.
Is the CTR deadline measured in business days or calendar days?
Calendar days. The rule says 15 days following the day of the transaction, and FinCEN's CTR instructions describe it as calendar days. The regulation provides no extension when day 15 lands on a weekend or holiday, so the conservative practice is to file by the prior business day.
What dollar amount triggers a CTR?
More than $10,000 in currency, in or out, by or on behalf of one person during one business day (31 CFR 1010.311). Exactly $10,000 does not trigger the requirement. Cash in and cash out are aggregated separately and are not netted: an $8,000 deposit and an $8,000 withdrawal the same day do not require a CTR, but two $6,000 deposits do.
How are multiple transactions aggregated for CTR purposes?
Multiple currency transactions are treated as one transaction when the institution has knowledge they are by or on behalf of the same person and total more than $10,000 in cash in or cash out during one business day (31 CFR 1010.313(b)). Aggregation spans all branches, and deposits made at night, over a weekend, or on a holiday are treated as received on the next business day.
How long must a bank keep copies of filed CTRs?
Five years from the date of the report (31 CFR 1010.306(a)(2)).
Who can be exempted from CTR filing?
Phase I exempt persons (banks, government agencies, and listed public companies and their subsidiaries) and Phase II exempt persons (qualifying non-listed businesses and payroll customers that meet the 31 CFR 1020.315 criteria, designated with FinCEN Form 110). Exemption removes the CTR obligation for that customer's transactions but not suspicious-activity monitoring or SAR duties.
What about customers who split cash to stay under $10,000?
Structuring transactions to evade the CTR requirement is a federal crime (31 U.S.C. 5324), whether or not the individual amounts are under the threshold. Suspected structuring calls for a suspicious activity report review; a SAR is required for suspicious transactions aggregating $5,000 or more.
This calculator is provided for general informational purposes only. It is not legal advice, not a substitute for reading the regulation, and not a representation of how any particular regulator or examiner will interpret a specific set of facts. Where a rule is ambiguous, the tool applies the more conservative reading and says so. Confirm results against the current regulation text and your institution's counsel and disclosed policies before relying on them.
The 15-day clock starts whether or not anyone opened a task.
Canarie turns CTR and SAR obligations into owned, deadline-tracked work with evidence capture, so filing timeliness is provable when the examiner pulls the sample.