Regulatory Alerts2001-07-26
Added
FinCEN Ruling 2001-1: CTR Filing and Aggregation for Affiliate Banks
FinCEN determines that both the bank receiving cash and the bank holding the account are technically required to file a Currency Transaction Report for a $12,000 deposit made through an agent bank, but only one report must be filed to avoid duplication. The filing institution must list the affected account numbers and mark the transaction as an "Affiliate Transaction(s)" to notify law enforcement that the account or physical transaction occurred elsewhere. Regarding aggregation, a bank must aggregate multiple cash transactions conducted by the same person on the same business day at its agent bank only if it has knowledge of those transactions through its systems or personnel.
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