When it comes to Currency Transaction Reports (CTRs), institutions need to ensure they are appropriately detecting reportable transactions, completing the form correctly and submitting it within the required timeframe. If you’ve ever completed a CTR, you’ve likely noticed that some fields are designated with an asterisk (critical fields) while other fields are not (non-critical fields). We often get questions about whether non-critical fields should be completed.
FinCEN’s Frequently Asked Questions (FAQs), for CTRs, clearly address this, stating:
As explained in FinCEN’s March 2012 guidance (FIN-2012-G002), for both critical and non-critical elements, financial institutions should complete those Items for which they have relevant information, regardless of whether or not the individual Items are deemed critical for technical filing purposes.
In other words, if you have the information to complete a non-critical field, you should. Keep in mind, this doesn’t require you to obtain or request non-critical information for purposes of completing the form. For instance, the FAQs go on to say …a financial institution may leave non-critical fields without an asterisk blank when information is not readily available.
To learn more be sure to check out our webinar, “All About CTRs”, which is available now OnDemand.
A few of our attendees had this to say:
- This was a great presentation for my staff. As always, the information was presented in an easy to comprehend format and effectively covered the need-to-know.
- Very useful. I finally got some clarification on things I’ve been wanting to know.
- I found the exemptions section really helpful, as well as pointers on aggregation.
Published 2026/11/08
