Definition
Currency Transaction Report (CTR)
A report a financial institution files with FinCEN when a customer conducts a cash transaction of more than $10,000 in a single business day. The trigger is aggregated across a single day of related deposits or withdrawals, and the filing deadline is 15 calendar days after the day of the transaction. CTRs are not confidential in the way SARs are; a firm may confirm a CTR was filed, but if a customer breaks up cash transactions to stay under the $10,000 threshold, that is 'structuring,' and the firm must file a SAR as well.
A client brings $11,500 in cash into a branch to open a securities account. The firm files a CTR with FinCEN within 15 calendar days. If the client had brought the same amount in three separate cash deposits of $4,000, $4,000, and $3,500 in one week, the firm would file both a CTR (for the aggregated cash) and a SAR (for the structuring pattern).
Students often confuse the CTR threshold with the SAR threshold. A CTR is triggered by cash of more than $10,000 in one business day, regardless of whether anything looks suspicious. A SAR is triggered by suspicion of illegal activity, with dollar minimums of $5,000 (suspect identified) or $25,000 (no suspect). Structuring transactions to stay under the CTR threshold is itself suspicious and requires a SAR.
How is Currency Transaction Report (CTR) tested on the exam?
- Recognizing the $10,000 cash trigger for a CTR
- Distinguishing a CTR (mechanical cash trigger) from a SAR (suspicion trigger)
- Applying the 15 calendar-day filing deadline
- Identifying structuring as a SAR trigger, not a way to avoid a CTR
- Knowing CTRs are filed with FinCEN, not directly with the SEC or FINRA
Regulatory limits
Regulatory Limits
| Description | Limit | Notes |
|---|---|---|
| CTR trigger | More than $10,000 cash in a single business day | Aggregated across related cash transactions during that day. |
| Filing deadline | 15 calendar days after the transaction | - |
| Filing recipient | FinCEN | Uses FinCEN Form 112. |
| Structuring | Any amount below $10,000 designed to avoid the CTR | Triggers a SAR in addition to any required CTR. |
CTR = Cash Ten thousand Report. Over $10,000 in cash in one day, file within 15 days with FinCEN. If someone splits the cash to avoid the CTR, that is structuring and also needs a SAR.
Practice questions
Test your understanding with the questions below. Pick an answer to reveal the explanation.
A customer deposits $12,000 in cash to fund a securities purchase. Which report is required?
B is correct. A single cash transaction over $10,000 triggers a CTR, filed with FinCEN within 15 calendar days. Without suspicious circumstances, no SAR is required. A and C add a SAR the facts do not support. D ignores the mechanical cash trigger.
The exam separates SAR triggers (suspicion) from CTR triggers (cash amount). One large legitimate cash deposit is a CTR without a SAR.
A customer makes three cash deposits of $3,500 on three consecutive days to avoid a CTR. What must the firm do?
C is correct. Structuring transactions to stay under the $10,000 CTR threshold is itself a violation and requires a SAR. A CTR is not automatically required, because no single day exceeded $10,000. D ignores the structuring rule.
Structuring is a favorite exam pattern. The intent to avoid a CTR is the trigger, not the raw dollar totals.
Which of the following is the correct filing deadline for a Currency Transaction Report?
A is correct. CTRs are filed with FinCEN within 15 calendar days of the transaction. B and C are SAR deadlines. D is not a real rule.
The exam pairs SAR deadlines (30/60 days) against the CTR deadline (15 days). Do not swap them.
What concepts relate to Currency Transaction Report (CTR)?
This term is part of this cluster :
Where does Currency Transaction Report (CTR) appear on the Series 6 exam?
This term is tested in the following FINRA Series 6 topic areas: