FinCEN Proposes Tweaks to CTR Filings

The Financial Crimes Enforcement Network is proposing changes to the Currency Transaction Reports banks file under the Bank Secrecy Act to reflect better the ways that institutions use CTRs.

For example, because more and more holding or parent companies are filing CTRs on behalf of subsidiaries, FinCEN proposed a new part of the CTR to record separate locations for where the report is filed and where the transaction took place, without requiring duplicative data entry.

The revised CTR would also facilitate reporting dollar values of multiple transactions without filing multiple CTRs, indicate “shared branching” transactions and clarify which employees count as a “teller.” Comments on the proposed changes are due by April 2.