Compliance Blog

Yesterday, FinCEN released a CTR pamphlet. 

The Financial Crimes Enforcement Network (FinCEN) is providing an educational pamphlet, “Notice to Customers: A CTR Reference Guide,” for financial institutions and their customers containing information on the currency transaction reporting (CTR) requirement. FinCEN is providing this pamphlet as a resource for financial institutions to help address questions frequently asked by their customers. The pamphlet, which can be provided to customers, uses plain language to explain the CTR reporting requirement to those who may not be familiar with a financial institution’s obligations under the Bank Secrecy Act (BSA). For example, the pamphlet explains that large currency transactions are not illegal, and that financial institutions are required to obtain information from their customers when these transactions do occur. The pamphlet does not alter in any way a financial institution’s BSA reporting requirements and explains that if a customer attempts to break up, i.e. “structure,” transactions in order to evade the CTR reporting requirement there are potential civil and criminal consequences. In the pamphlet, FinCEN explains what constitutes structuring and provides examples of structured transactions.

• Read the full press release here.
• See the black and white version here. 
• See the color version here.

I called to FinCEN to see if they were producing a "credit union version" or if they'd let institutions find and replace "customer" with "member."  I haven't heard back yet on that.  But I do think this pamphlet could be useful to address member concerns when they ask about currency transaction reports. 

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Did you ever dream of working at NAFCU?  Of course not.  But in any event, there's an opening here for a Regulatory Affairs Assistant.  The successful candidate would be working in Arlington, Virginia.  Oh, and they'd get to work with me.  (Maybe I shouldn't have mentioned that.)  Anyway, with today's economy, I thought you might know of someone who might be interested.  Get the details here.