History

• Congress passed the Currency and Foreign Transactions Reporting Act in 1970. The legislation, now commonly referred to as the Bank Secrecy Act, included a provision that required banks and financial institutions to begin completing CTRs. In 1986, The Money Laundering Control Act, gave financial institutions the ability to complete Suspicious Activity Reports. SARs are completed when individuals or businesses conduct suspicious transactions that do not exceed the $10,000 threshold stated in the BSA for CTRs.
  
  

CTR Information

• A CTR must include the name, physical address, Social Security number and the form of government issued identification used by the individual that conducted the transaction. When transactions that require CTRs are conducted on behalf of a business or entity, the financial institution must also record the Tax Identification Number and name of the organization involved, as well information pertaining to the agent or person conducting the transaction. Financial institutions and individuals failing to complete required CTRs face fines.
  
  

Purpose of Reporting Large Cash Transactions

• Criminal enterprises often try to conceal the origins of cash derived from illegal activities by passing it through various accounts in a process called money laundering. The movement of cash between several accounts in a short space of time makes it difficult for the government to trace its origin. Some people attempt to avoid CTRs by structuring transactions. If someone cashes several checks that in total exceed $10,000 within a 24-hour period, the BSA requires banks to complete a CTR. In addition, many banks complete SARs when people cash checks for amounts close to $10,000.
  
  

Monetary Instrument Logs

• In addition to CTRs, financial institutions must also complete and maintain Monetary Instrument Logs when customers conduct certain transactions involving cash amounts of between $3,000 and $10,000. MILs are less detailed versions of CTRs and are not triggered by people cashing checks. However if someone cashes a check and purchases a money order or cashier's check for more than $3,000, the financial institution conducting the transaction must complete a MIL. The BSA requires financial institutions to complete MILs for all money transfers above $3,000, including the conversion of a regular check into certified or official check.