Administrative Rulings

Pursuant to its authority at 31 CFR Part 1010 Subpart G, the Financial Crimes Enforcement Network (FinCEN) may issue administrative rulings interpreting the Bank Secrecy Act (BSA) or FinCEN’s implementing regulations at 31 CFR Chapter X. Administrative rulings that are published on FinCEN’s website provide guidance to financial institutions and other requestors in complying with applicable BSA regulations. Published administrative rulings have precedential value and may be relied upon by others that are similarly situated. FinCEN does not respond substantively to every request for an administrative ruling and reserves the right to decline to provide a ruling to any request. Administrative ruling requests must be made in accordance with the requirements set out at 31 CFR 1010.711 and may be submitted to administrative.rulings@fincen.gov.

| Casinos, Depository Institutions, Money Services Businesses
Currency Transaction Reporting: Aggregation

Dear [ ]:
This letter responds to your letter dated June 4, 2001, on behalf of [ ] (the “Bank”),requesting a determination whether the Bank is required under 31 U.S.C. § 5313, and itsimplementing regulations found at 31 C.F.R. § 103.22, to aggregate multiple currencytransactions for purposes…

| Casinos, Depository Institutions, Money Services Businesses
Currency Transaction Reporting: Completing a CTR and Aggregation

Dear [ ]:
This responds to your letter dated February 25, 2000, on behalf [ ] (the “Bank”), to theFinancial Crimes Enforcement Network (“FinCEN”). In that letter, you requested a ruling on theapplication of the rules relating to the filing of a currency transaction report (“CTR”),…

| Casinos, Depository Institutions, Money Services Businesses
Currency Transaction Reporting: Guidance on Completing CTR Section A "Person(s) on Whose Behalf Transaction(s) is Conducted

Dear [ ]:
You have asked how [ ](the "Bank") should properly report certain currency transactionson Form 4789 (a "CTR") in the circumstances described below. Your question was originallyraised in a letter dated August 16, 2000, which was forwarded to the Financial CrimesEnforcement Network…

| Casinos, Depository Institutions, Money Services Businesses
(Formerly known as 92-1) How should a financial institution complete a CTR when multiple transactions are aggregated and reported on a single form and all or part of the information called for in the form may not be known?

This ruling, formerly known as 92-2, 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:

31 U.S.C. 5313 -- Reports on Domestic Coins and…

| Casinos, Depository Institutions, Money Services Businesses
(Formerly known as 89-5) How does a financial institution fulfill the requirement that it furnish information about the person on whose behalf a reportable currency transaction is being conducted?

This ruling, formerly known as 89-5, was posted to the website on May 18, 2010; it was previously published via the Federal Register. Please note that this ruling pre-dates the customer identification rules that have since been implemented.

Facts

No. 1. Linda Scott has had an…

| Depository Institutions
(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…

| Depository Institutions
(Superseded by subsequent changes to 31 CFR 103.22) (Formerly known as 89-1)
| Casinos, Depository Institutions, Insurance Industry, Money Services Businesses, Mortgage Co/Broker, Precious Metals/Jewelry Industry, Securities and Futures
(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-…

| Casinos, Depository Institutions, Money Services Businesses
(Superseded by subsequent changes to 31 U.S.C. 5318) (Formerly known as 88-1)
| Depository Institutions
(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