We agree that your bank should file a CTR, since issuing a cashier’s check constitutes a currency transaction between the bank and your customer, and it involves more than $10,000.

There are several exemptions to the CTR filing requirements, including an exemption for currency transactions between banks and state agencies. However, there is no currency changing hands between your bank and the State Treasurer’s office in this case. Consequently, that exemption does not apply, and we are not aware of other exemptions that might apply here.

For resources related to our guidance, please see:

• FinCEN Regulations, 31 CFR 1010.311 (“Each financial institution other than a casino shall file a report of each 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, except as otherwise provided in this section.”) 

• FinCEN Regulations, 31 CFR 1020.315 (“(a) No bank is required to file a report otherwise required by § 1010.311 with respect to any transaction in currency between an exempt person and such bank . . . . (b) For purposes of this section, an exempt person is: . . . (2) A department or agency of the United States, of any State, or of any political subdivision of any State; . . .”)