ARLINGTON, Va.—Credit unions are being reminded of 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.
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. Calcano noted that 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
- When to complete Item 3 for multiple transactions involving multiple Part I sections when more than one role applies to that conductor