CTR Filing, Exemptions & Recordkeeping Retention *(OUTLINE + BULLET BODY)*

A SAR is a judgment call — you saw something suspicious and you chose to report it. A CTR is something else entirely: it's a mechanical, mandatory, math-based report. There's no "I had a feeling." If a customer moves more than ten thousand dollars in cash in one business day, the report gets filed — full stop, even if the customer is your most trusted account holder. On the CAMS® exam, the trap is mixing these two up, or thinking you can skip a CTR because the activity "looks fine." You can't. This lecture nails down the cash-reporting machinery: the threshold, the aggregation rule, the exemptions that genuinely exist, the funds-transfer Travel Rule, and how long you keep all of it.

- A **Currency Transaction Report (CTR)** is filed by a financial institution for each transaction in **currency** of **more than $10,000** — that is, over $10,000, not $10,000 even. Source: BSA, **31 CFR 1010.311**; filed on **FinCEN Form 112**. - "Currency" means physical **cash** — coin and paper money, U.S. or foreign. It is NOT triggered by checks, wires, or ACH on their own. The CTR is about cash crossing the teller line. - The CTR is **not** a suspicion report. It is filed regardless of whether the activity looks legitimate — it is purely about the dollar amount of cash. - Filing deadline: within **15 days** of the transaction (electronically through the BSA E-Filing system).

- Multiple cash transactions are **aggregated**: a CTR is required when cash-in or cash-out totals **more than $10,000 by or on behalf of the same person in one business day**. Five separate $2,500 cash deposits by the same customer in one day = a reportable $12,500. Source: **31 CFR 1010.313**. - Aggregation applies **across branches** of the same institution — a deposit at one branch and another at a second branch on the same day still aggregate. Institutions need systems to roll up same-day cash activity firm-wide. - "By or on behalf of the same person" captures transactions a customer conducts for someone else — the report identifies both the conductor and the person on whose behalf it's done. - **Structuring tie-in:** deliberately keeping each transaction just under $10,000 to dodge the CTR is **illegal structuring** under **31 USC 5324**, even if the underlying cash is clean. Structuring is itself a crime and a SAR trigger.

- The BSA allows institutions to **exempt** certain customers from routine CTR filing — to cut low-value paperwork — under **31 CFR 1020.315**. - **Phase I** exempt persons: banks, government agencies/departments, and entities whose stock is listed on major U.S. exchanges (and certain subsidiaries). These generate predictable, high-volume cash and pose low ML risk. - **Phase II** exempt persons: qualifying **non-listed businesses** and **payroll customers** that maintain a transaction account, are eligible (some business types are ineligible), and have an established pattern of frequent large cash transactions. - Exemption is **optional**, must be **documented**, and the customer must be **monitored** and the designation **reviewed annually**. An exemption is not a free pass — suspicious activity by an exempt customer still requires a **SAR**, and the exemption can be revoked. - Ineligible businesses (e.g., certain cash-intensive types like those dealing heavily in cash that the rule excludes) cannot be exempted. Know that exemptions are limited and conditional, not blanket.

- The BSA **Recordkeeping and Travel Rule** (FinCEN/Federal Reserve joint rule, **31 CFR 1010.410(e)–(f)**) applies to **transmittals of funds of $3,000 or more**. - The **Recordkeeping Rule** requires institutions to **collect and retain** specified information about the transmittor and recipient for transfers of $3,000+. - The **Travel Rule** requires the originator's institution to **"travel"** (pass on) certain information **to the next financial institution** in the payment chain — including the **transmittor's name, address, account number, the amount, the date, and the recipient's institution and (where available) name/account**. - Purpose: keep a usable paper trail across the chain of banks so investigators can follow funds. Note this BSA Travel Rule (wires, $3,000) is the conceptual ancestor of the **FATF Recommendation 16** crypto Travel Rule we'll cover in Domain 6 — same idea, different rails. - Don't confuse the **$3,000** funds-transfer recordkeeping threshold with the **$10,000** CTR threshold — the exam loves to swap these numbers.

- The BSA general recordkeeping standard is **five (5) years**. Source: **31 CFR 1010.430** and related provisions. - This applies to **CTRs, SARs, the SAR supporting documentation, CDD/identification records, and funds-transfer records** — keep them retrievable for **five years** from filing or from account closure as applicable. - SAR confidentiality continues to apply to retained SAR records — they are kept, but not disclosed to the subject (tipping-off prohibition, **31 CFR 1020.320(e)**). - Exam cue: the default BSA retention answer is **five years**, measured from the date of the report or the relevant event.

So, the cash-reporting machine in five numbers: a CTR is filed for cash over ten thousand dollars in a single business day, aggregating across branches and across multiple transactions by or for the same person; exemptions exist for low-risk Phase I and Phase II customers but must be documented, monitored, and reviewed annually; the funds-transfer Travel Rule kicks in at three thousand dollars and forces originator information to travel down the payment chain; structuring to dodge the ten-thousand-dollar threshold is itself a federal crime; and you keep all of it for five years. Mechanical, not judgmental — that's the CTR mindset. Next, we move from reports you file to information you share: the two information-sharing channels created by the USA PATRIOT Act — 314(a) and 314(b) — plus working with law enforcement.