Currency Transaction Report (CTR)

What is a CTR (Currency Transaction Report)?

A Currency Transaction Report (CTR) is a regulatory filing required when a US financial institution processes a cash transaction exceeding USD 10,000 in a single business day — either as a single transaction or as multiple transactions aggregated by or on behalf of one person. CTRs are mandated under the Bank Secrecy Act (BSA) and filed electronically with the Financial Crimes Enforcement Network (FinCEN) on FinCEN Form 112.

CTRs are one of the foundational data flows in the US AML framework. They give law enforcement and regulators visibility into the high-value cash activity moving through the banking system, supporting investigations into money laundering, tax evasion, terrorist financing, and other financial crime — see our wider AML compliance complete guide and sanctions screening AML guide.

CTR full form in banking

CTR stands for Currency Transaction Report. The term is used universally in US banking, financial services, and regulatory compliance contexts to refer to the BSA-mandated filing for cash transactions above the reporting threshold.

Who must file CTRs

The obligation to file CTRs applies to a broad set of US financial institutions. National and state-chartered banks, federal and state-chartered credit unions, savings associations, US branches and agencies of foreign banks, money services businesses (MSBs), casinos and card clubs above defined revenue thresholds, and broker-dealers in securities all fall within scope.

Any institution that handles physical cash from customers must be in a position to identify reportable transactions and submit the CTR on time — typically through a unified AML screening and monitoring platform that flags qualifying transactions automatically.

The USD 10,000 threshold

The CTR is triggered by cash transactions exceeding USD 10,000 — not USD 10,000 exactly. A USD 10,000.01 deposit is reportable; a USD 10,000.00 deposit is not.

Aggregation

The threshold applies to aggregate cash activity by or on behalf of a single person on a single business day. Two USD 6,000 deposits by the same customer on the same business day exceed the threshold collectively and trigger a CTR — even though no single transaction does. Institutions must therefore aggregate cash activity at the customer level, not just at the transaction level.

What counts as cash

"Cash" in the CTR context means physical currency and certain cash equivalents — including coin, currency, and certain monetary instruments in specific contexts (such as cashier's cheques in some casino transactions). It does not include wire transfers, ACH transactions, cheque deposits drawn on other accounts, or electronic payments.

CTR filing process

A CTR filing follows a structured workflow that runs from identification through electronic submission and recordkeeping:

1. Identification — the institution's teller, branch system, or AML platform identifies that a customer's cash activity in a single business day has exceeded USD 10,000, either through a single transaction or through aggregation.
2. Information capture — the institution captures the customer's identifying information (name, address, date of birth, SSN or tax identifier, occupation), the transaction details (amount, currency, date, type, account), and identifying information for any third party on whose behalf the transaction was conducted.
3. Electronic filing — the CTR is filed electronically through the FinCEN BSA E-Filing System on Form 112 within 15 calendar days of the transaction.
4. Recordkeeping — the institution retains a copy of the CTR and all supporting documentation for at least five years from the date of filing, available for regulatory or law-enforcement inspection.

CTR vs SAR vs STR

CTRs and SARs/STRs are both BSA-era filings, but they answer different questions and follow different triggers.

Filing	Trigger	Requires suspicion?	Threshold	Deadline
CTR	Cash transactions exceeding USD 10,000 in a single business day	No — purely threshold-based	USD 10,000 (cash only)	15 calendar days
SAR	Suspicion of money laundering, terrorist financing, or predicate offence	Yes	USD 5,000 (general); USD 25,000 for transactions with no identified suspect	30 calendar days (extendable to 60)
STR	Same as SAR — used internationally outside the US	Yes	Varies by jurisdiction	"As soon as practicable" in most regimes

A single transaction can trigger both filings. A USD 50,000 cash deposit by a customer whose profile and history make the deposit suspicious would generate both a CTR (because of the threshold) and a SAR (because of the suspicion) — filed separately, with no cross-reference visible to the customer.

Structuring: avoiding CTRs is a federal crime

A defining feature of the CTR regime is that deliberately structuring transactions to avoid the CTR threshold is itself a federal crime under 31 U.S.C. § 5324 — separate from any underlying money-laundering offence. A customer who deposits USD 9,500 on Monday, USD 9,000 on Tuesday, and USD 8,500 on Wednesday — specifically to keep each deposit below the threshold — has committed structuring.

Structuring is one of the most consistently flagged placement-stage typologies in AML programmes — see our wider treatment of money-laundering typologies for context. A customer's structuring pattern almost always generates both monitoring alerts and a SAR filing — even though no individual transaction crosses the CTR threshold.

Exemptions

Not every customer's qualifying cash transactions require a CTR. The BSA provides a structured CTR exemption framework for two categories of customer.

Phase I Exemptions cover transactions of banks, government entities, and listed public companies meeting defined criteria. Phase II Exemptions cover qualifying non-listed business customers and payroll customers whose cash transactions meet detailed eligibility tests. Phase II exemptions require periodic re-verification and ongoing monitoring of the exempt customer's activity.

Exemptions reduce filing burden without reducing visibility — the exempt customer's activity is still monitored, and any unusual or suspicious activity still triggers a SAR. Our five pillars of an AML programme writeup covers where exempt-customer monitoring fits into the broader framework.

CTRs and transaction monitoring

Although CTRs are threshold-based rather than suspicion-based, they sit inside the broader AML framework. CTR data feeds transaction monitoring scenarios — structuring detection, customer behavioural baselines, peer-group analysis — and supports investigators reconstructing illicit cash flows.

A customer whose CTR history shows a sudden increase in high-value cash activity, or whose cash pattern is inconsistent with their stated business, is a classic unusual-activity signal worth dedicated review. Our transaction monitoring primer covers the detection-side detail.