Regulatory Alerts2002-10-03
Added
FinCEN Ruling 2003-1: Currency Transaction Reporting Aggregation
FinCEN determines that a money transmitter must aggregate currency transactions conducted by its agents on the same day if the transmitter has knowledge of them, triggering a Currency Transaction Report filing obligation when the total exceeds $10,000. The transmitter, rather than the individual agents, bears the reporting responsibility because it is the financial institution with knowledge of the aggregated cash-in amounts. This obligation applies regardless of whether the funds are wired to the same or different recipients, although separate cash-out transactions may require additional reporting.
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