Cash Transaction Report: Form 112, Filing, and Penalties

A cash transaction report is what a bank or other financial institution files with the Financial Crimes Enforcement Network whenever a customer’s cash activity crosses $10,000 in a single business day. The form is FinCEN Form 112, it goes in electronically through the BSA E-Filing System, and the institution has 15 days from the transaction date to submit it.¹ The obligation comes from the Bank Secrecy Act, which uses the reports to help detect money laundering, tax evasion, and related financial crimes.²

When a CTR Has to Be Filed

Any deposit, withdrawal, currency exchange, or other cash transfer of more than $10,000 triggers the report.³ Both U.S. and foreign currency count. When the money is foreign, the institution converts it at that business day’s exchange rate to see whether the total crosses the threshold.⁴

Only physical cash counts. Checks, wire transfers, money orders, and electronic payments do not go toward the $10,000 figure, even when they arrive alongside a cash transaction. A customer who deposits $6,000 in cash and $8,000 by personal check has done $6,000 of reportable cash activity. Deposits left in a night drop or over a weekend are treated as received on the next business day.⁵

Multiple Transactions in the Same Day

The threshold is not per-transaction. If a financial institution knows that several cash transactions during the same business day are by or on behalf of the same person, it must add them together, and any combined total over $10,000 triggers a CTR — deposits, withdrawals, or a mix.⁵ A customer who deposits $4,000 in the morning and withdraws $7,000 that afternoon has generated $11,000 in reportable currency activity for the day.

Aggregation reaches across branches. When the same person conducts cash transactions at two different branches of the same bank on the same day, the amounts get combined, and institutions are expected to run systems that can track a single person’s cash activity across every location.⁶

Who Files the Report

The filing obligation sits with the institution handling the cash, not the customer. The entities required to file CTRs include federally insured banks, credit unions, savings associations, and trust companies; money service businesses such as check cashers, money transmitters, currency exchangers, and sellers of money orders or traveler’s checks; brokers and dealers in securities; and casinos and card clubs with gross annual gaming revenue over $1 million. All of them use the same form and the same $10,000 threshold.⁶

Non-Financial Businesses Use Form 8300

Businesses that are not financial institutions but receive more than $10,000 in cash from a customer, in one transaction or in related transactions, have a separate reporting obligation. Auto dealerships, attorneys, jewelers, real estate agents, and similar businesses file IRS/FinCEN Form 8300 rather than Form 112.⁷ The 15-day filing deadline is the same, but Form 8300 adds a step that catches many businesses off guard: a written statement must be sent to each person named in the report by January 31 of the following year, letting them know the form was filed with the IRS.⁸ CTR filers have no customer-notification requirement.

Exemptions

Not every large cash customer needs a CTR every time. Banks can exempt certain low-risk customers from ongoing reporting, and the rules divide them into two groups.

Phase I covers the lowest-risk categories: other domestic banks, federal, state, local, and interstate government entities, companies listed on major national stock exchanges, and subsidiaries at least 51% owned by such listed companies. For listed companies and their subsidiaries, the bank still has to file a Designation of Exempt Person (DOEP) report and conduct annual reviews.⁹

Phase II applies to non-listed businesses and to payroll customers that regularly withdraw more than $10,000 to pay employees in cash. To qualify, the customer must have conducted at least five reportable cash transactions within a year, held an account for at least two months, and derived no more than 50% of gross revenue from ineligible activities. The bank has to file a DOEP within 30 days of the first transaction it wants to exempt and review eligibility at least once a year.¹⁰ Certain business types can never qualify for Phase II regardless of history: car dealerships, law and accounting firms, pawn brokers, real estate brokers, casinos, investment advisors, auctioneers, and marijuana-related businesses are on the ineligible list.¹¹ A business doing several things can still qualify as long as no more than 50% of its gross revenue comes from ineligible categories.¹²

What Goes on Form 112

The form captures three sets of information: who conducted the transaction, who benefited from it, and what actually happened.

For the person at the counter, the institution records full legal name, date of birth, address, and taxpayer identification number (SSN or ITIN). Identity has to be verified with a government-issued document — driver’s license, state ID, passport, or alien registration card — and the form logs the document type, issuing authority, and ID number.⁶

When someone conducts a transaction for another person or a business, the beneficiary’s information is captured separately: for an entity, that means legal name, headquarters address, and EIN. Sole proprietorships trip people up. Because a sole proprietorship is not legally separate from its owner, the form is completed with the individual owner’s personal information (name, gender, date of birth) rather than as a separate entity.¹³

Transaction details include the total dollar amount, split between U.S. and foreign currency, and the nature of the transaction (deposit, withdrawal, currency exchange, or other transfer). The filing institution then adds its own legal name, address, EIN, the branch where the transaction happened, and its primary federal regulator code.⁶

How and When It’s Filed

FinCEN requires every CTR to be filed electronically through the BSA E-Filing System. Paper submissions are not accepted unless the institution has a specific exemption.⁶ The deadline is 15 days after the date of the reportable transaction.¹ A rejection for formatting errors does not extend that window, so batch filers need enough lead time to catch and resubmit before the 15 days run out.

Once filed, the institution must keep a copy of each CTR and all supporting documentation, including the ID records taken from the person conducting the transaction, for five years from the date of the report.¹ Those records have to be available to FinCEN or any examining authority on request.

Structuring Is a Separate Crime

Intentionally breaking a large cash transaction into smaller pieces to stay under $10,000 is called structuring, and it is a standalone federal offense.¹⁴ It does not matter whether the money itself is clean. A person who deposits $9,000 today and $9,000 tomorrow specifically to dodge a CTR has committed a crime regardless of where the cash came from.

Two sub-$10,000 deposits on consecutive days are not automatically structuring. What matters is whether the person split the transactions apart for the purpose of evading the reporting requirement.¹⁵ Financial institutions cannot help customers do it either. Advising a customer to break up a deposit to stay below $10,000 exposes both the customer and the employee to criminal liability.

Penalties for Not Filing

The Bank Secrecy Act imposes civil and criminal penalties, and they reach both the institution and the individual officers or employees who took part in a violation.

Civil

A willful failure to file a required CTR can bring a civil penalty of up to the greater of $25,000 or the amount involved in the transaction, capped at $100,000. Negligent violations carry up to $500 per incident, but a pattern of negligent failures can add up to $50,000 on top. Repeat violators face enhanced penalties of up to three times the profit gained or twice the maximum penalty for the violation.¹⁶ Individual partners, directors, officers, and employees can be held personally liable when they willfully participate in a violation or act with gross negligence. Willfulness on the civil side does not require intent to break the law; reckless disregard or willful blindness to obvious compliance failures is enough.¹⁷

Criminal

Willfully violating BSA reporting requirements is a felony punishable by up to five years in prison and a $250,000 fine. If the violation is part of a pattern of illegal activity involving more than $100,000 in a 12-month period, the penalties jump to up to 10 years in prison and a $500,000 fine.¹⁸

Structuring has its own criminal statute: up to five years in prison with fines under Title 18 sentencing guidelines, and up to 10 years if the structuring accompanies other illegal activity or involves more than $100,000 over 12 months.¹⁴ A convicted officer or employee of a financial institution must also repay any bonus received during the calendar year of the violation or the year after.¹⁸

1
eCFR. 31 CFR 1010.306 – Filing of Reports
2
Office of the Law Revision Counsel. 31 USC 5313 – Reports on Domestic Coins and Currency Transactions
3
eCFR. 31 CFR 1010.311 – Reports of Transactions in Currency
4
Financial Crimes Enforcement Network. Frequently Asked Questions Concerning Completion of Part II of FinCEN Form 104, Currency Transaction Report
5
eCFR. 31 CFR 1010.313 – Aggregation
6
Financial Crimes Enforcement Network. FinCEN Currency Transaction Report Electronic Filing Requirements
7
Internal Revenue Service. IRS Form 8300 Reference Guide
8
Internal Revenue Service. Form 8300 and Reporting Cash Payments of Over $10,000
9
Financial Crimes Enforcement Network. Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements
10
Regulations.gov. Agency Information Collection Activities – Transactions of Exempt Persons Regulations and Designation of Exempt Person Report
11
FFIEC BSA/AML Manual. Assessing Compliance with BSA Regulatory Requirements – Transactions of Exempt Persons
12
eCFR. 31 CFR 1020.315 – Transactions of Exempt Persons
13
Financial Crimes Enforcement Network. FinCEN CTR (Form 112) Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a DBA Name
14
Office of the Law Revision Counsel. 31 USC 5324 – Structuring Transactions to Evade Reporting Requirement
15
Financial Crimes Enforcement Network. Suspicious Activity Reporting (Structuring)
16
Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
17
Internal Revenue Service. Bank Secrecy Act Penalties
18
Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties