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January 28, 2020

What changed in FinCEN's CTR filing instructions?

Compliance BlogA new NAFCU Compliance Blog post explains changes made by the Financial Crimes Enforcement Network (FinCEN) to its Currency Transaction Report (CTR) Electronic Filing Instructions, which provide technical corrections and clarifications for complex currency-related situations.

In the blog, NAFCU Regulatory Compliance Specialist Alma Calcano reminds credit unions that they are required to electronically file CTRs for any currency – defined as coin and paper money – transaction of more than $10,000 made by, through, or to the credit union.

FinCEN last year updated the filing instructions and the corresponding answer to a question in the CTR FAQs. Among some technical corrections, the changes include:

  • how reporters should complete Part I of the CTR when multiple Item 2 roles apply to the person identified in Part I; and
  • when to complete Item 3 for multiple transactions involving multiple Part I sections when more than one role applies to that conductor.

Calcano further reviews these changes in detail and provides additional resources for CTR filing to help credit unions comply. Read the full blog.

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In addition to the Compliance Blog, NAFCU offers myriad compliance resources. Of note, registration for the association's Spring Regulatory Compliance School – happening March 16-20 in Arlington, Va. – is now open. Throughout the week, attendees will hear from compliance experts on key issues, including examinations, fair lending, Bank Secrecy Act, and more.