Gunster – Banking and Financial Services, February 2009
Today, the Financial Crimes Enforcement Network(“FinCEN”) announced the release of an educational pamphlet on the Currency Transaction Reporting (“CTR”) requirements for financial institutions and their customers (“Pamphlet”).
The Pamphlet addresses CTR reporting requirements and uses plain language for those who may not be familiar with a financial institution’s obligations under the Bank Secrecy Act (“BSA”).
The Pamphlet may be used as a resource for financial institutions to help address questions asked by customers regarding CTR reporting requirements. FinCEN does not require that Financial institutions use the Pamphlet, but rather provides it as a useful resource for communicating with customers, particularly in situations when the financial institution expects to handle large amounts of currency, or when a customer has questions about a certain currency transaction.
The Pamphlet explains that large currency transactions are not prohibited and that the filing of CTRs is required regardless of the reasons forthe currency transaction. The Pamphlet alsoexplains that customers who intend to break up transactions in order to evade the CTR reporting requirement are subject to imprisonment and/orfines of up to $250,000.
The Pamphlet was developed by consulting with law enforcement, regulatory bodies and the financial industry.
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Should you wish to receive further information concerning matters discussed in this publication, please contact:
Clemente L. Vazquez-Bello305.376.6082 ▪ [email protected]
Andres A. Fernandez305.376.6097 ▪ [email protected]
Marina Olman305.376.6069 ▪ [email protected]
This publication is for general information only. It is not legal advice, and legal counsel should becontacted before any action is taken which might be influenced by this publication.
