Administrative Rulings

Administrative letter rulings drafted by the Financial Crimes Enforcement Network (FinCEN) are issued pursuant to our authority as the administrator of the Bank Secrecy Act, if the facts and circumstances, issues, and analyses that appear in an administrative letter ruling are of general interest to financial institutions then the letter ruling is published on our website. Published letter rulings often express an opinion about a new issue; apply an established theory or analysis to a set of facts that differs materially from facts or circumstances that have been previously considered; or provide a new interpretation of Title 31 of the United States Code, or any other statute granting FinCEN authority. A summary of the variety of regulatory releases, which also includes an outline of the effect of the various releases on financial institutions that are subject to the regulatory provision at issue, is available here [HTML | PDF]

| 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