FIN 2013 R001 AppendixI
FIN 2013 R001 AppendixI
Examples of the Completion of the FinCEN Currency Transaction Report (“CTR”) for
Transactions Involving Armored Car Services
On the same business day, Bank A receives currency deposits for the accounts of two
accountholders, as follows:
1.1. Jack’s Restaurant is a large cash business that is a customer of Bank A. Bank A has
contracted with Armored Car Service One (“ACS One”) to pick up the cash from Jack’s
Restaurant and transport it to Bank A’s account with the Federal Reserve. ACS One picks up
$21,000 in cash from Jack’s Restaurant and delivers it to the Federal Reserve.
Bank A will complete the CTR reflecting this transaction as follows:
Part I (1 of 1) will show Jack’s Restaurant’s corporate information, checking boxes 2c
(“Person on whose behalf transaction was conducted”) and “Check if entity,” and
inserting in item 21 the deposited amount ($21,000) and Jack Restaurant’s account
number.
Part II will show the $21,000 deposited in section 25a, checking box 24 (“Armored Car
(FI Contract)”).
Part III will contain Bank A’s information as the financial institution where transaction
took place.
The completed CTR is shown on pages 6 through 9 of this guidance.
1.2. Bob’s Warehouse is a large cash business that is a customer of Bank A. Bob’s Warehouse
has contracted with Armored Car Service One (“ACS One”) to pick up the cash from the
warehouse and transport it to Bank A for deposit into Bob’s Warehouse account. ACS One
picks up $21,000 in cash from Bob’s Warehouse and delivers the cash to Bank A.
Bank A will complete the CTR reflecting this transaction as follows:
Part I (1 of 2) will show Bob’s Warehouse corporate information, checking box 2c
(“Person on whose behalf transaction was conducted”) and “Check if entity,” and
inserting in item 21 the deposited amount ($21,000) and Bob’s Warehouse account
number.
Part I (2 of 2) will show ACS One’s corporate information, checking boxes 2d (“Courier
service (private)”) and “Check if entity,” and inserting in item 21 the amount delivered
by ACS One on behalf of Bob’s Warehouse ($21,000) and Bob’s Warehouse account
number.
Part II will show the $21,000 deposited in section 25a.
Part III will contain Bank A’s information as the financial institution where transaction
took place.
The completed CTR is shown on pages 10 through 14 of this guidance.
Even though ACS One made a currency delivery of $21,000 acting on behalf of a person
other than Bank A, no separate CTRs need to be filed on ACS One’s delivery.
5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 2 of 4
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 3 of 4
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Other (specify)
*29 Primary federal regulator Office of the Comptroller of the Currency (OCC)
*35 State DC
39 Financial institution ID type Research, Statistics, Supervision and Discount (RSSD) number
ID number 12365422
*42 Date Filed (Date filed will be auto-populated when the form is signed.)
Page 4 of 4
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 2 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Account number
+ -
Page 3 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 4 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Other (specify)
*29 Primary federal regulator Office of the Comptroller of the Currency (OCC)
*35 State DC
39 Financial institution ID type Research, Statistics, Supervision and Discount (RSSD) number
ID number 12365422
*42 Date Filed (Date filed will be auto-populated when the form is signed.)
Page 5 of 5
2. Bank B – Multiple transactions aggregating to a reportable amount
On the same banking day, Bank B receives currency deposits for the accounts of five
accountholders, as follows:
2.1. Mr. Adams receives three deposits (for individual amounts in excess of $10,000) for a total
of $37,500 in currency: $11,000 is delivered by ACS One, an armored car service working
on behalf of Bank B; $15,000 is deposited by Mr. Adams himself; and the balance, $11,500,
is delivered by ACS Two, an armored car service acting on Mr. Adams’s behalf.
2.1.1. If Bank B is able to determine which armored car service transactions were conducted on
behalf of the bank and which ones were conducted on behalf of the bank’s customer,
Bank B will complete the CTR reflecting this transaction as follows:
Part I (1 of 2) will show Mr. Adams’s personal information checking boxes 2a (“Person
conducting transaction on own behalf”) and 3 (“Multiple Transactions”), and inserting in
item 21 the total amount deposited ($37,500), and Mr. Adams’ account number.
Part I (2 of 2) will show ACS Two’s corporate information checking boxes 2d (“Courier
service (private)”) and “Check if entity,” and inserting in item 21 the $11,500 delivered
by ACS Two on Mr. Adams’s behalf and Mr. Adams’s account number.
Part II will show the total deposits of $37,500 in section 25a, checking box 24 (“Armored
Car (FI Contract)” to justify the $11,000 delivered by ACS One on Bank B’s behalf.
Part III will contain Bank B’s information as the financial institution where transaction
took place.
Parts I and II of the completed CTR are shown on pages 16 through 19 of this guidance.
2.1.2. If Bank B is unable to determine which armored car service transactions were conducted
on behalf of the bank and which ones were conducted on behalf of the bank’s customer,
Bank B will complete the CTR reflecting this transaction as follows:
Part I (1 of 3) will show Mr. Adams’s personal information, checking boxes 2a (“Person
conducting transaction on own behalf”) and 3 (“Multiple Transactions”), and inserting in
item 21 the total amount deposited ($37,500) and Mr. Adams’ account number.
Part I (2 of 3) will show ACS Two’s corporate information, checking boxes 2d (“Courier
service (private)”) and “Check if entity,” and inserting in item 21 the $11,500 delivered
by ACS Two and Mr. Adams’s account number.
Part I (3 of 3) will show ACS One’s corporate information, checking boxes 2d (“Courier
service (private)”) and “Check if entity,” and inserting in item 21 the $11,000 delivered
by ACS One and Mr. Adams’s account number.
Part II will show the total deposits of $37,500 in section 25a.
Part III will contain Bank B’s information as the financial institution where transaction
took place.
Parts I and II of the completed CTR are shown on pages 20 through 24 of this guidance.
15
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name A
Suffix
7 Gender Male
8 Alternate Name
Account number
+ -
Page 2 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 3 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 4 of 5
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name A
Suffix
7 Gender Male
8 Alternate Name
Account number
+ -
Page 2 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 3 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 4 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 5 of 6
2.2. Mr. Brown receives a total of $9,000 in currency delivered by ACS One acting on Mr.
Brown’s behalf. A CTR is not required as the total amount received does not exceed
$10,000.
2.3. Mr. Davis receives two deposits (individually in amounts exceeding $10,000) for a total of
$23,000 in currency: $10,500 is delivered by ACS Three acting on Mr. Davis’s behalf; the
balance, $12,500, is delivered by a third party, John Smith.
Bank B will complete the CTR reflecting this transaction as follows:
Part I (1 of 3) will show Mr. Davis’s personal information, checking boxes 2c (“Person
on whose behalf transaction was conducted”) and 3 (“Multiple Transactions”), and
inserting in item 21 the total amount deposited ($23,000) and Mr. Davis’s account
number.
Part I (2 of 3) will show ACS Three’s corporate information, checking boxes 2d
(“Courier service (private)”) and “Check if entity,” and inserting in item 21 the $10,500
delivered by ACS Three on Mr. Davis’s behalf and Mr. Davis’s account number.
Part I (3 of 3) will show Mr. Smith’s personal information, checking box 2b (“Person
conducting transaction for another”), and inserting in item 21 the $12,500 delivered by
John Smith and Mr. Davis’s account number.
Part II will show the total deposits of $23,000 in section 25a.
Part III will contain Bank B’s information as the financial institution where transaction
took place.
Parts I and II of the completed CTR are shown on pages 26 through 30 of this guidance.
2.4. Mr. Edwards receives a total of $8,600 in currency delivered by ACS Three acting on Mr.
Edwards’s behalf. A CTR is not required, as the total amount received does not exceed
$10,000.
25
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name B
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Note: Field 7 (Gender) is an optional field that is required only if the FI has the information.
Page 2 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 3 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name T
Suffix
7 Gender Male
8 Alternate Name
9a NAICS Code
19 E-mail address
Account number
+ -
Page 4 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 5 of 6
2.5. Mr. Foster receives three deposits (individually in amounts below $10,000) for a total of
$12,000 in currency; all deposits are delivered by armored car services acting on Mr. Foster’s
behalf: $3,000 is delivered by ACS One, $4,000 is delivered by ACS Two, and $5,000 is
delivered by ACS Three.
Bank B will complete the CTR reflecting this transaction as follows:
Part I (1 of 1) will show Mr. Foster’s personal information, checking boxes 2c (“Person
on whose behalf transaction was conducted”) and 3 (“Multiple Transactions”), and
inserting in item 21 the total amount deposited ($12,000) and Mr. Foster’s account
number.
Part II will show the total deposits of $12,000 in section 25a, checking box 24
(“Aggregated Transactions”).
Part III will contain Bank B’s information as the financial institution where transaction
took place.
Parts I and II of the completed CTR are shown on pages 32 through 34 of this guidance.
During the same business day, acting on behalf of Bank B’s customers ACS One made total
currency deliveries for $12,000 ( Case 2.2 $9,000 and Case 2.5 $3,000 ), ACS Two made total
currency deliveries of $15,500 (Case 2.1.1. $11,500 and Case 2.5 $4,000), and ACS Three made
total currency deliveries of $24,100 (Case 2.3 $10,500, Case 2.4 $8,600, and Case 2.5 $5,000).
However, Bank B’s reporting obligation regarding transactions conducted by armored car
services on behalf of its customers is satisfied by filing a CTR aggregated by customer. Bank B
is not required to file additional, separate CTRs aggregating all armored car service
deliveries/pick-ups conducted on behalf of its customers on the same business day.
31
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name D
Suffix
7 Gender Male
8 Alternate Name
9a NAICS Code
Account number
+ -
Page 2 of 4
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 3 of 4
3. Bank C - Armored car service delivering on behalf of a third party for the credit of the
account of a bank’s customer
3.1. Bank C receives a $20,000 delivery from Armored Car Service Four (ACS Four), acting on
instructions from a shipper, Mexican Casa de Cambio (Casa de Cambio Reynosa), to be
credited to the account of Mr. Green, the bank’s customer.
Bank C will complete the CTR reporting this transaction as follows:
Part I (1 of 3) will show Mr. Green’s personal information, checking box 2c (“Person on
whose behalf transaction was conducted”), and inserting in item 21 the total amount
deposited ($20,000) and Mr. Green’s account number.
Part I (2 of 3) will show ACS Four’s corporate information, checking boxes 2d (“Courier
service (private)”) and “Check if entity,” and inserting in item 21 the $20,000 delivered
by ACS Four on behalf of Casa de Cambio Reynosa and Mr. Green’s account number.
Part I (3 of 3) will show Casa de Cambio Reynosa’s corporate information as an
additional person on whose behalf the same $20,000 was conducted, checking boxes 2c
(“Person on whose behalf transaction was conducted”) and “Check if entity,” and
inserting in item 21 the total amount deposited ($20,000)and Mr. Green’s account
number.
Part II will show the total deposits of $20,000 in section 25a.
Part III will contain Bank C’s information as the financial institution where transaction
took place.
The completed CTR is shown on pages 36 through 41 of this guidance.
Even though ACS Four made a currency delivery of $20,000 acting on behalf of a person
other than Bank C, no separate CTRs need to be filed on ACS Four’s delivery.
35
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
*1 Type of filing Initial report Correct/amend prior report FinCEN directed Backfiling
By providing my PIN, I acknowledge that I am electronically signing the BSA report submitted.
6 Middle name O
Suffix
7 Gender
8 Alternate Name
9a NAICS Code
Account number
+ -
Note: Field 7 (Gender) is an optional field that is required only if the FI has the information.
Page 2 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
Account number
+ -
Page 3 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
6 Middle name
Suffix
7 Gender
8 Alternate Name
9a NAICS Code
19 E-mail address
Account number
+ -
Page 4 of 6
WARNING: PRINTED VERSIONS OF THE BSA E-FILING FORMS ARE NOT FOR SUBMISSION
AND WILL NOT BE PROCESSED BY FINCEN.
Currency Transaction Report
Home
Part II Amount and Type of Transaction(s). Check all boxes that apply.
24 Armored car (FI Contract) ATM Mail Deposit or Shipment Night Deposit Aggregated transactions
*25 CASH IN: (in U.S. dollar equivalent) *27 CASH OUT: (in U.S. dollar equivalent)
.00
Foreign Country
+ -
26 Foreign Cash in
Foreign Country
+ -
28 Foreign Cash out
Page 5 of 6
41