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| Administrative Ruling
(Formerly known as 89-2) When a customer has established bank accounts for each of several establishments that it owns, and the bank has exempted one or more of those accounts, how does the bank aggregate the customer`s currency transactions?
This ruling, formerly known as 89-2, was posted to the website on May 18, 2010; it was previously published via the Federal Register. Please note that references in this ruling to CTR exemptions and form numbers are outdated. Facts X Company (``X'') operates two fast-food restaurants and a…
| Administrative Ruling
(Superseded by subsequent changes to 31 CFR 103.22) (Formerly known as 89-1)
| Administrative Ruling
(Formerly known as 88-5) Does a financial institution havea duty to file a CTR on currency transactions where the financial institution never physically receives the cash because it uses an armored car service to collect, transport and process
Facts X State Bank (the "Bank") and Acme Armored Car Service ("Acme") have entered into a contract which provides for Acme to collect, transport and process revenues received from Bank customers: Each day, Acme picks up cash, checks, and deposit tickets from Little Z, a non-exempt customer of the…
| Guidance
FIN-1988-R002 (Formerly 88-2)
Ruling This ruling, formerly known as 88-2, was posted to the website on May 18, 2010; it was previously published via the Federal Register. Please note that references in this ruling to CTR form numbers are outdated.   Facts A customer walks into B National Bank ("B") with $ 15,000 in…
| Administrative Ruling
(Superseded by subsequent changes to 31 CFR 103.22) (Formerly known as 88-4)
| Administrative Ruling
(Superseded by subsequent changes to 31 CFR 103.22) (Formerly known as 88-3)
| Administrative Ruling
(Formerly known as 88-2) When, if ever, should a bank filea CMIR on behalf of its customer, when the customer is importing or exporting more than $ 10,000 in currency or monetary instruments?his ruling, formerly known as 88-2, was posted to the website
| Administrative Ruling
(Superseded by subsequent changes to 31 U.S.C. 5318) (Formerly known as 88-1)
| Federal Register Notice
Amendments to the Bank Secrecy Act Regulations Regarding Reporting and Recordkeeping by Card Clubs
Guidance
GUIDANCE ON INTERPRETING FINANCIAL INSTITUTION POLICIES IN RELATION TO RECORDKEEPING REQUIREMENTS UNDER 31 C.F.R. §103.29
The Financial Crimes Enforcement Network (FinCEN) receives numerous questions concerning compliance with the Bank Secrecy Act (BSA) recordkeeping requirement found in 31 C.F.R. §103.29. This section requires financial institutions to verify a customer’s identity and retain records of certain…