Spring 2004-10 New Currency Transaction Report form released
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Spring 2004-10 New Currency Transaction Report form released

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Number 55
Spring 2004

New Currency Transaction Report form released

FinCEN released in March a new CTR form, identified as “FinCEN Form 104, which replaces the Internal Revenue Service CTR Form 4789 presently in use.

FinCEN-which stands for the U.S. Department of the Treasury’s “Financial Crimes Enforcement Network”-is the federal agency that now administers the Bank Secrecy Act, the nation’s main anti-money laundering statute.

Each financial institution must file a currency transaction report for each currency transaction that exceeds $10,000. These include deposits, withdrawals, currency exchanges, loan payment, check cashing, etc.

Financial institutions may continue to use IRS Form 4789 until August 31, 2004.


31 C.F.R. Sec. 103.22-Reports of transactions in currency:


Each financial institution shall file a report of each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000.

Multiple currency transactions shall be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day. Deposits made at night or over a weekend or holiday shall be treated as if received on the next business day following the deposit.


31 C.F.R. Sec. 103.63-Structured transactions:


No person shall for the purpose of evading the reporting requirements of Sec. 103.22, structure any transaction with one or more domestic financial institutions.

Structuring a transaction includes, but is not limited to, the breaking down of a single sum of currency exceeding $10,000 into smaller sums, or conducting a series of currency transactions. The transaction or transactions need not exceed the $10,000 reporting threshold at any single financial institution on any single day in order to constitute structuring.

© 2004 Goldman Antonetti