Compliance Blog

Last week, GAO released a study on CTRs.  Report GAO-08-355, titled "Increased Use of Exemption Provisions Could Reduce Currency Transaction Reporting While Maintaining Usefulness to Law Enforcement Efforts" is available here.

In GAO's words:

Why GAO Did This Study
To aid law enforcement efforts against financial crimes, under the Bank Secrecy Act (BSA) depository institutions must file the Treasury Department’s Financial Crimes Enforcement Network’s (FinCEN) currency transaction report (CTR) form on their customers’ cash transactions of more than $10,000. While FinCEN’s regulations allow institutions to exempt certain customers, over 15 million CTRs were filed in 2006. Public Law 109-351 directed GAO to report on (1) the usefulness of CTRs to law enforcement; (2) depository institutions’ costs of meeting CTR requirements; and (3) ways to encourage use of exemptions to avoid unnecessary CTRs. Among other things, GAO obtained data from FinCEN on CTRs and exemptions from 2004 to 2006, surveyed 115 state and local law enforcement agencies and 680 depository institutions, held structured interviews with officials of federal agencies and depository institutions, and reviewed relevant laws and regulations.
What GAO Recommends
GAO recommends that the Secretary of the Treasury direct FinCEN to consider routinely publishing summary information on CTR use, revise certain regulations that deter exemptions, and provide additional guidance and Web-based material to help depository institutions interpret exemption requirements. FinCEN concurred with our regulatory and guidance recommendations and stated that it will consider options for providing feedback on CTR use. (Emphasis added.)

For BSA junkies, the reports is full of CTR-related information and statistics.