TL;DR: A Currency Transaction Report is a mechanical BSA filing on FinCEN Form 112 for currency in or out of more than $10,000 by or on behalf of one person in a single business day. FinCEN's Year in Review for FY2024 records 20.5 million CTRs, about 56,160 filings a day. The report does not require suspicion. When the same cash activity looks designed to evade that filing, the institution files a SAR instead of, or in addition to, the CTR.
A Report of Cash, Not Suspicion
A Currency Transaction Report is a BSA report that records a currency transaction of more than $10,000 conducted by, through, or to a financial institution. Under 31 CFR 1010.311, the obligation covers deposits, withdrawals, exchanges of currency, and other payments or transfers. Currency means coin and paper money of the United States or another country that is legal tender and customarily used as a medium of exchange. Checks, wires, ACH, and card payments do not trigger a CTR, even when they exceed $10,000.
The CTR is not a finding of illicit activity. The institution does not need to know, suspect, or have reason to suspect anything about the customer. A restaurant depositing Saturday receipts and a mule emptying an account generate the same form if the currency side clears the line. The report is a standardized cash trail for law enforcement, not a narrative of wrongdoing.
The FFIEC BSA/AML Examination Manual treats currency transaction reporting as a distinct test from suspicious activity reporting. Examiners sample whether the bank identified reportable cash, aggregated it across branches, verified identity, filed on time, and kept copies. A missed CTR is a regulatory failure even when the cash was legitimate. A filed CTR does not satisfy a SAR obligation when the facts support suspicion.
Customers may be told that a CTR will be filed. Telling a customer about a SAR is a separate violation. That disclosure difference is the fastest way to tell the two reports apart at the window.
Why the $10,000 Line Still Drives Work
The reporting threshold is more than $10,000 in a business day, not $10,000 even. A $10,000 cash deposit is not reportable on its own. A $10,000.01 deposit is. Treasury set that dollar amount in 1972. It has not been indexed for inflation.
Volume reflects that freeze. According to GAO report GAO-25-106500, CTR filings rose about 62 percent from fiscal year 2002 through 2023. The same report estimates that an inflation-adjusted threshold in 2023 would have been about $72,880, and that using that figure would have cut CTR volume by at least 90 percent each year since 2014. FinCEN has agreed to review thresholds, aggregation, and unused form fields under the Anti-Money Laundering Act of 2020. Until a rule changes, banks still file at $10,000.
Investigators still use reports near that line. IRS Publication 6129 (February 2026) states that 66.8 percent of IRS Criminal Investigation cases opened in FY2025 had at least one CTR associated with a primary subject. FinCEN's October 2025 FAQs, issued with the federal banking agencies, restated that transactions at or near the threshold do not require a SAR unless the institution has reason to suspect they were designed to evade reporting.
Aggregation and Exemptions Are Where Programs Break
Most CTR misses are aggregation misses. Under 31 CFR 1010.313, multiple currency transactions are treated as a single transaction when the institution has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during one business day. Knowledge includes what a teller, officer, or existing computer or manual system can see. Domestic branches are one institution for this purpose. Night, weekend, and holiday deposits are treated as received on the next business day.
Cash in and cash out do not net. A customer who deposits $8,000 and withdraws $7,000 the same day has not crossed the line in either direction. A customer who deposits $6,000 at a branch and $5,000 at an ATM that afternoon has, if the systems know both deposits belong to the same person. Armored-car drops, cash monetary-instrument purchases, currency-funded wires, and prepaid loads sit in the same bucket when they are currency.
FinCEN's FIN-2012-G001 guidance sets a rebuttable presumption: separately incorporated entities are independent persons. Common ownership alone does not require combining their cash. The presumption falls when the facts show the businesses are not independent — same address and staff, accounts used to pay each other's bills, or business accounts funding the owner's personal expenses. Once the institution makes that determination, it aggregates going forward. Using beneficial ownership data to paper over a missing CTR after the fact is the kind of gap an AML lookback review is designed to find.
Who can be exempted
Banks may treat certain customers as exempt persons under 31 CFR 1020.315 so routine cash above $10,000 does not generate a CTR. Phase I generally covers other banks operating in the United States, government entities, and listed businesses and qualifying subsidiaries. Phase II covers eligible non-listed businesses and payroll customers after five or more reportable currency transactions in a year and at least two months as a customer, or less time after a documented risk-based analysis. Ineligible lines of business listed in the rule, including many money services and gaming operations, cannot be Phase II exempted if they make up more than 50 percent of gross revenue.
Exemption is not a monitoring holiday. FinCEN is explicit that banks still have a SAR obligation on exempt customers. Phase II relief applies only to transactions conducted through exemptible accounts. A convenience store exempted on its deposit account still needs a CTR if it buys a cashier's check with cash that never posts to that account. Designation of Exempt Person filings and annual reviews still apply to listed businesses and Phase II customers.
What Form 112 actually requires
The current form is the FinCEN CTR, Form 112, filed only through the BSA E-Filing System. Paper Form 4789 is gone. A completed report must be filed within 15 calendar days after the date of the transaction, and copies must be retained for five years from the date of the report, per 31 CFR 1010.306 and the FFIEC BSA/AML Examination Manual. Critical fields cannot be left blank; the filer provides the information or marks unknown. FinCEN still expects the most complete identifying information the institution has, including identity documents used to verify the person conducting the transaction. "Known customer" is not an acceptable substitute.
Aggregated filings are where data quality slips. When several sub-threshold cash movements add up after the fact, the teller often never collected ID on each one. The FFIEC manual still expects reasonable effort to complete person and transactor fields from existing records. Incomplete aggregated CTRs are required filings. They are also weaker intelligence — the same volume-without-detail problem FinCEN has been pushing on SAR narratives. Institutions that invest in stronger SAR narratives should apply the same discipline to who, on whose behalf, which accounts, and which locations on Form 112.
CTR Versus SAR
Confusing the two reports produces both over-filing and under-filing. The CTR answers whether more than $10,000 in currency moved, in one direction, for one person, in one business day. The SAR answers whether the institution knows, suspects, or has reason to suspect money laundering, a BSA evasion, or activity with no apparent lawful purpose, generally at $5,000 or more. Both filings can apply to the same customer on the same day. Neither substitutes for the other.
Structuring is the bridge between the two. Structuring in banking is conducting currency transactions in any amount, at one or more institutions, on one or more days, in any manner, for the purpose of evading the CTR requirement. It is a federal crime under 31 U.S.C. 5324 even when the underlying funds are legitimate. The FFIEC manual is direct: when a bank suspects a person is structuring to evade CTR filing, it must file a SAR. The CTR still gets filed if the aggregated cash actually exceeded $10,000. If the customer succeeded in staying under the line, the SAR is the report that exists.
A teller who coaches a customer to keep a deposit under $10,000 is assisting in structuring. A monitoring rule that fires solely because deposits landed between $8,000 and $9,999 is not a completed SAR analysis. Design shows up in behavior after disclosure, splits across branches, cash that does not match the stated business, and coordinated third-party deposits. Those facts belong in the SAR, and often in a 314(b) request when the pattern appears to span other banks. Sphinx covers that channel in its explainer on FinCEN 314(b) information sharing.
CTR controls sit inside the internal-controls pillar of a BSA program: identification at the window, same-day aggregation, exemption governance, timely e-filing, and five-year retention. Independent testing should sample those controls the way it samples SAR decisioning. The architecture is the same five pillars of an AML compliance program; the CTR is one of the few requirements that still turns on a hard dollar amount rather than a judgment call.
Where Sphinx Fits
Sphinx operates as an AI-native compliance layer inside the systems analysts use. Agents can reconstruct same-day cash activity across accounts and locations, surface exemption and aggregation exceptions, and assemble the chronology a reviewer needs when a CTR file should become a structuring SAR. Every step is logged so the institution can show an examiner how the decision was reached. The CTR remains a threshold filing. What changes is whether the miss, the exemption review, and the SAR that should have accompanied it are documented before the exam, not during it.
Frequently Asked Questions
What is the CTR reporting threshold?
A financial institution must file a CTR when currency in or currency out exceeds $10,000 by or on behalf of one person in a single business day. Transactions of exactly $10,000 are not reportable. Multiple smaller cash movements are combined when the institution has knowledge they are by or on behalf of the same person.
Does a CTR mean the customer did something illegal?
No. A CTR is a threshold report, not a suspicion report. Legitimate cash businesses generate large numbers of CTRs every year. Illicit activity can appear on a CTR as well, which is why law enforcement queries the database, but the filing itself does not accuse the customer of a crime.
What is the difference between a CTR and a SAR?
A CTR records cash above $10,000 with no judgment required. A SAR reports activity the institution knows, suspects, or has reason to suspect is illicit or designed to evade the BSA, generally at $5,000 or more. The same facts can require both. Customers may be told about a CTR. They may not be told about a SAR.
How soon must FinCEN Form 112 be filed?
The CTR must be filed electronically through FinCEN's BSA E-Filing System within 15 calendar days after the date of the transaction. The institution must keep a copy for five years from the date of the report. Paper CTRs are not accepted.
Does exempting a customer from CTRs remove the SAR obligation?
No. Phase I and Phase II exemptions relieve the bank of filing CTRs on qualifying currency transactions through exemptible accounts. Suspicious activity monitoring and SAR filing continue for exempt customers. Transactions that do not run through the exemptible account can still require a CTR.
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