Under the Bank Secrecy Act, a bank must combine multiple cash transactions into a single Currency Transaction Report when it knows they are by or on behalf of the same person and the total tops $10,000 in one business day. That combined filing is what the aggregate CTR filing requirements are built around: individual transactions that would each fly under the radar become reportable once they add up. The report itself is FinCEN Form 112, filed electronically through the BSA E-Filing System.1Financial Crimes Enforcement Network. FinCEN Currency Transaction Report Electronic Filing Instructions
What Triggers Aggregation
The rule lives at 31 CFR § 1010.313. It tells financial institutions to treat multiple cash transactions as a single transaction when the institution knows they are by or on behalf of the same person and the combined total is more than $10,000 during one business day.2eCFR. 31 CFR 1010.313 – Aggregation It covers both deposits and withdrawals. A $6,000 deposit at one branch in the morning and a $5,000 deposit at another branch that afternoon are aggregated, because the combined figure crosses the threshold.
The business-day clock resets at the institution’s close of business. Anything received overnight, over a weekend, or on a holiday counts as if it came in on the next business day.2eCFR. 31 CFR 1010.313 – Aggregation Banks run automated software that watches accounts across branches to catch smaller transactions that add up. Separately, 31 CFR § 1010.311 requires a CTR for any single cash transaction that itself exceeds $10,000, without any need to aggregate.3eCFR. 31 CFR 1010.311 – Filing Obligations for Reports of Transactions in Currency
Aggregating Businesses With a Common Owner
A common question: does the bank combine cash transactions from two separately incorporated businesses that share an owner? The default answer is no. Separately incorporated entities are presumed to be independent persons, and their transactions are not automatically lumped together.4Financial Crimes Enforcement Network. Currency Transaction Report Aggregation for Businesses with Common Ownership
That presumption breaks when the businesses are not truly operating independently. Banks weigh factors like shared employees and address, one entity’s account routinely paying another’s bills, or business accounts covering the owner’s personal expenses. Once the bank concludes the entities are not genuinely separate, their cash transactions get aggregated going forward, and each entity appears in its own section of the CTR.4Financial Crimes Enforcement Network. Currency Transaction Report Aggregation for Businesses with Common Ownership
What the Report Captures
Preparing an aggregate CTR means the bank collects identification from both the person conducting the transaction and, if different, the person on whose behalf it is made. The form requires full legal name, Social Security Number or Employer Identification Number, residential address, date of birth, and occupation.5Financial Crimes Enforcement Network. FinCEN Currency Transaction Report
The teller verifies identity using a government-issued photo ID, such as a driver’s license, passport, or alien registration card, and the form records the document number, issuing authority, and type.5Financial Crimes Enforcement Network. FinCEN Currency Transaction Report The bank also records its own legal name, branch address, and federal regulator, along with the account numbers and totals broken into cash in and cash out.
Foreign currency has a specific rule. Total cash-in and cash-out amounts must be converted to U.S. dollars using that business day’s exchange rate. But the separate foreign currency sub-fields stay in the original denomination and are not converted.6FinCEN. Frequently Asked Questions Concerning Completion of Part II of FinCEN Form 104, Currency Transaction Report
How and When the Bank Files
All CTRs go through the BSA E-Filing System on FinCEN’s secure network.7Financial Crimes Enforcement Network. BSA E-Filing System Paper filing is no longer accepted.8FinCEN. Bank Secrecy Act Filing Information The deadline is 15 days after the day the reportable transaction occurred.9eCFR. 31 CFR 1010.306 – Filing of Reports The system returns a tracking ID once the upload is complete, and institutions keep that confirmation as proof of timely filing.
One thing to know as a customer: there is no federal prohibition on a bank telling you that a CTR is being filed. It is a routine regulatory filing triggered by the dollar amount, not by any suspicion of wrongdoing. FinCEN publishes a customer-facing pamphlet explaining what a CTR is and why the bank needs your information.10Financial Crimes Enforcement Network. Notice to Customers: A CTR Reference Guide
Who Is Exempt From CTR Filing
Not every customer triggers a CTR. Federal regulations create two tiers of exemptions for entities that routinely handle large amounts of cash.
The first tier is automatic: domestic operations of other banks, any federal, state, or local government department or agency, domestic operations of companies listed on the New York Stock Exchange, NYSE American, or designated as a NASDAQ National Market Security, and domestic operations of a U.S.-organized subsidiary where the listed parent owns at least 51 percent. Banks do not even need to file an exemption form for federal agencies, other banks, or Federal Reserve Banks.11FFIEC. Transactions of Exempt Persons
The second tier covers non-listed businesses that frequently deal in cash. A bank can designate a commercial customer as exempt if the business has kept an account at the bank for at least two months (or less with a documented risk assessment), frequently conducts cash transactions above $10,000, and is incorporated or organized under U.S. or state law. FinCEN has indicated that five or more reportable cash transactions within a year can establish the “frequent” threshold. The bank must file a one-time Designation of Exempt Person report through the BSA E-Filing System within 30 calendar days after the first reportable transaction it wishes to exempt.11FFIEC. Transactions of Exempt Persons
Structuring Deposits to Avoid the Threshold Is a Federal Crime
Deliberately breaking up cash transactions to stay below $10,000 is called structuring, and it is a federal crime under 31 U.S.C. § 5324 regardless of whether the underlying money is legal.12Office of the Law Revision Counsel. 31 USC 5324 – Structuring Transactions to Evade Reporting Requirement The statute reaches the person making the deposits, anyone who assists in structuring, and anyone who causes a bank to file an inaccurate report.
The pattern takes several forms. Depositing amounts just under $10,000 across multiple days is the most common. Visiting multiple branches on the same day or sending different people to make deposits on your behalf also counts. So does spreading transactions across days if the purpose is to dodge the reporting requirement.13Financial Crimes Enforcement Network. Suspicious Activity Reporting – Structuring
A structuring conviction carries up to five years in prison and fines under Title 18. If the structuring is connected to other illegal activity involving more than $100,000 over a 12-month period, the maximum jumps to 10 years.14Office of the Law Revision Counsel. 31 USC 5324 – Structuring Transactions to Evade Reporting Requirement The government can also seize the cash. The critical element is intent: the prosecution must prove the transactions were broken up for the purpose of evading the reporting requirement. That intent can be inferred from a pattern of just-under-the-limit deposits.
Penalties for Failing to File or Aggregate
The penalty range depends on whether the failure was negligent or willful, and whether it was isolated or part of a pattern. A negligent violation runs up to $500 per incident, and FinCEN can add up to $50,000 more when a bank establishes a pattern of negligence. A willful violation draws a civil penalty of up to the greater of $25,000 or the amount involved in the transaction, capped at $100,000 per violation. These civil penalties apply to the institution and to individual partners, directors, officers, or employees responsible.15Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
Criminal exposure goes further. A willful BSA violation carries fines up to $250,000 and up to five years in prison. When the violation is tied to other illegal activity involving more than $100,000 in a 12-month period, the maximum rises to $500,000 in fines and 10 years. Courts can order forfeiture of any profits gained from the violation, and employees of financial institutions may be required to repay bonuses received during the year of the violation.16Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties
What the CTR Is Not
Two related filings often get confused with the CTR, and the distinctions matter if you are trying to work out which rule applies to you.
A Suspicious Activity Report is not an aggregate CTR. A CTR is objective and automatic once cash crosses $10,000. A SAR is judgment-based, filed when a transaction involves at least $5,000 and the bank suspects illegal proceeds, an attempt to evade BSA rules, or no apparent lawful purpose.17eCFR. 31 CFR 1020.320 – Reports by Banks of Suspicious Transactions Unlike a CTR, a SAR is subject to a strict federal prohibition on disclosure to the subject.
IRS Form 8300 is also not a CTR. It applies to non-bank trades or businesses that receive more than $10,000 in cash in a single transaction or in related transactions across a 12-month period. Its definition of “cash” is broader than a bank’s and can pick up cashier’s checks, bank drafts, traveler’s checks, and money orders with a face value of $10,000 or less in certain designated transactions.18Internal Revenue Service. IRS Form 8300 Reference Guide A one-off personal sale, such as selling your own car for $12,000 cash, does not trigger Form 8300 because it is not a trade or business.