"For the first time in the 25-year history of the Bank Secrecy Act's requirement that CTRs be filed by financial institutions, the form has been revised to reduce the amount of regulatory information required," said Stanley E. Morris, Director of FinCEN.
"This revision is mutually beneficial to law enforcement and the financial community because it focuses on the quality of information rather than the quantity."
FinCEN establishes policies to prevent and detect money laundering and also serves as the central source of financial intelligence in support of financial crimes investigations. As part of its regulatory responsibilities, FinCEN administers the Bank Secrecy Act, which requires that domestic financial institutions file a CTR on each single or multiple "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." CTRs have a high degree of usefulness in criminal, tax, and regulatory investigations and proceedings.
The revised CTR requires only basic information, such as who conducted the transaction, on whose behalf it was conducted, the amount, a description of the transaction, and where it occurred. The revised form also lists broad categories of transactions which will make it easier to complete and analyze.
FinCEN revised the CTR in cooperation with the Bank Secrecy Act Advisory Group, which is comprised of about 30 private (bank and non-bank) and government representatives. The Treasury Department established this Group in March of 1994 as a "think tank" to recommend ways for both private and public sectors to implement anti-money laundering efforts.
An ADVANCE COPY of the revised CTR will allow financial institutions to train employees and make other necessary changes required in order to complete and file the revised CTR, effective October 1, 1995. Filers must continue to use the current CTR Form 4789 (Rev. July 1994) for reportable transactions that occur before October 1, 1995.
An ADVANCE COPY of the revised CTR Form 4789 (Rev. October 1995) may be ordered from the Internal Revenue Service (IRS) Forms Distribution Centers by calling 1-800-TAX-Form (1-800-829-3676).
FinCEN is drafting additional guidance on how to complete the revised CTR. These guidelines will be distributed to financial institutions in the near future. To assist in developing this guidance, questions concerning the revised CTR are encouraged. Members of the financial community interested in asking questions should call the IRS Enterprise Computing Center-Detroit, Compliance Review Group, at 313-226-4431 or FinCEN at 1-800-949-2732. You may also write to FinCEN, Office of Financial Institutions Policy, ATTN: CTR, P.O. Box 39, Vienna, VA 22183.
Specifications for magnetic filing of the revised CTR will be issued soon by the IRS Detroit Computing Center. Any questions concerning magnetic filing should be directed to the IRS Detroit Computing Center, ATTN: CTR Magnetic Media Coordinator, P.O. Box 33604, Detroit, MI 48232-5604.