“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 said it’s difficult to understand the nature and amounts of reported cash transactions using the data supplied following the pre-2020 filing instructions. So FinCEN 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 2019.

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.

Almost immediately, FinCEN suspended implementation of that Ruling, partly because of the challenges presented by developments surrounding the coronavirus and the COVID-19 pandemic. Where does that leave financial institutions that had already implemented the Ruling? Can institutions use part of that ruling to clarify their filings on some sole proprietor DBAs?

In this 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—

• Types of transactions affected
• Item 2 and conductors in dual capacities
• Using item 3 to report multiple transactions
• Item 3 vs. Item 24e “Aggregated 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
• Impact of the suspension of FIN-2020-R002
• Two ways to handle rounding dollar amounts upward
• Deposits and withdrawals involving joint accounts
• Other CTR filing sticking points

WHO SHOULD ATTEND:

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