“In an effort to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement, we are clarifying the requirements of financial institutions reporting on currency transactions ….” (FinCEN Ruling FIN-2020-R001, February 10, 2020)

Translation: Your CTR filing is about to become more complex and time-consuming.

Law enforcement uses data from Currency Transaction Reports in its investigations of money laundering and other criminal activity. Unfortunately, law enforcement says it’s difficult to understand the nature and amounts of reported cash transactions using the data supplied following the current filing instructions. So FinCEN has made some changes, not in the information we collect for CTR filing, but in how we break that information down and report it.

In October 2019, FinCEN announced changes in the instructions for completing items 2 and 3 on the CTR. The effective date for the item 2 changes was later postponed, and the revised instructions for item 3 were revised again in November.

On February 10, 2020, FinCEN Administrative Ruling FIN-2020-R001 announced significant changes to the filing instructions for CTRs involving sole proprietorships and entities operating under DBA business names.

In this special one-hour presentation, John Burnett will discuss each of the changes in detail, providing you with the information you will need to file CTRs that are compliant with the revised instructions. Topics to be covered include—

• Effective dates for each of the changes
• Types of transactions affected
• Item 2 and conductors in dual capacities
• Using item 3 to report multiple transactions
• Reporting involving sole proprietors
• The “spousal joint sole proprietorship” footnote
• Sole proprietorship TINs
• Reporting multiple DBAs
• Entities with multiple locations
• Entities using DBA names
• Which locations information to report

WHO SHOULD ATTEND:

BSA officers and staff, auditors, compliance officers, front-line