FinCEN’s new CTR instructions


Presented by: John Burnett
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FinCEN has just suspended the implementation of its most recent Ruling on the filing of CTRs for sole proprietorships and entities operating with DBA names. So, what are financial institutions supposed to be doing with those CTRs now?

"In an effort to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement, we are clarifying the requirements of financial institutions reporting on currency transactions …." (FinCEN Ruling FIN-2020-R001, February 10, 2020)

Translation: Your CTR filing is about to become more complex and time-consuming.

Law enforcement uses data from Currency Transaction Reports in its investigations of money laundering and other criminal activity. Unfortunately, law enforcement says it's difficult to understand the nature and amounts of reported cash transactions using the data supplied following the current filing instructions. So FinCEN has made some changes, not in the information we collect for CTR filing, but in how we break that information down and report it.

In October 2019, FinCEN announced changes in the instructions for completing items 2 and 3 on the CTR. The effective date for the item 2 changes was later postponed, and the revised instructions for item 3 were revised again in November.

On February 10, 2020, FinCEN Administrative Ruling FIN-2020-R001 announced significant changes to the filing instructions for CTRs involving sole proprietorships and entities operating under DBA business names.

And now, FinCEN has suspended implementation of that Ruling, partly because of the challenges presented by developments surrounding the coronavirus and the COVID-19 pandemic. Where does that leave financial institutions that have already implemented the Ruling?

In this special one-hour presentation, John Burnett will discuss each of the changes in detail, providing you with the information you will need to file CTRs that are compliant with the revised instructions. Topics to be covered include-

  • Effective dates for each of the changes
  • Types of transactions affected
  • Item 2 and conductors in dual capacities
  • Using item 3 to report multiple transactions
  • Reporting involving sole proprietors
  • The "spousal joint sole proprietorship" footnote
  • Sole proprietorship TINs
  • Reporting multiple DBAs
  • Entities with multiple locations
  • Entities using DBA names
  • Which locations information to report
  • Impact of the suspension of FIN-2020-R002

About the Speakers: John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking. He is also a graduate of the BAI's and the Massachusetts Banker Association's Schools of Banking.

He joined Cape Cod Bank and Trust Company in 1971 and assumed his role as Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc., and became a part of the BOL Team in June, 2004.

Mr. Burnett is a former member chair of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force, and has served on several ABA and Massachusetts Bankers seminar panels.

This program was recorded in its entirety in April 2020. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_ctr0420
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Friday 14 February, 2020.

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