Regulatory Alerts1989-06-21
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When a customer has established bank accounts for several establishments it owns, and the bank has exempted one or more of those accounts, how does the bank aggregate the customer's currency transactions
The Financial Crimes Enforcement Network's Ruling FIN-1989-R002 clarifies how financial institutions, specifically depository institutions, must aggregate currency transactions for customers with multiple accounts. Banks must aggregate multiple currency transactions as a single transaction if they know they are by or on behalf of any person and total over $10,000 in a business day, as required by Section 103.22 of the Bank Secrecy Act. For aggregation, banks should first total cash-in and cash-out transactions separately within each account; if an account's exemption limit is not exceeded, its transactions are not aggregated with others. However, if an account's total transactions exceed its exemption limit, the entire total for that account must be aggregated with totals from other accounts exceeding their limits, accounts without limits, and other reportable transactions by the same person, leading to a single Currency Transaction Report filing for the combined amount.
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