Currency Transaction Reports (CTRs) take a lot of time, effort, and energy. Not only do you need to ensure that you are appropriately detecting any reportable transactions, you must also make sure that you complete the forms correctly and submit them within the required timeframes.
If you are responsible for completing CTRs, you’ve more than likely noticed that some fields are designated with an asterisk (critical fields) while other fields are not (non-critical fields). Sometimes, there is confusion on when a non-critical field should be completed.
FinCEN’s Frequently Asked Questions (FAQs), 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 forms. 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.
During our BSA compliance reviews, we commonly see non-critical fields left blank when it’s clear the information is available, either within a financial institution’s system or other records. Some common non-critical field information we see omitted includes middle name/initial, occupation or type of business, phone number, e-mail address, etc.
Published
2024/06/28
