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We have a customer that recently purchased a $28,000 cashier’s check with cash to pay the winner of a drawing. The customer also recently deposited $77,000 in cash proceeds from the drawing. How do we fill out the currency transaction report (CTR) to incorporate both transactions? On Item 21 of the CTR form, we are supposed to list the total “cash in” amount for the entity, where we included the $77,000 deposit. But where do we add the cashier’s check purchase? Do we add a line to Item 21? Also, should we create a Part I (Person Involved in Transaction) for our bank for the cashier’s check purchase, because our bank was involved in that currency transaction?

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In our view, the appropriate place to list the individual amounts of the deposit and the cash purchase of the cashier’s check is in Item 25 on the CTR. Item 25 is used to identify the amount and type of each individual “cash in” transaction, along with the total of all the “cash in” transactions. The deposit amount would be listed on line 25a (Deposit(s)), and the cashier’s check purchase amount would be listed on line 25d (Purchase of negotiable instruments). The total “cash in” amount for this customer — the sum of the deposit and the cashier’s check purchase amount — would be listed on Item 25. Note that the total “cash in” amount also should be listed in Item 21, which is another place you must list the “total cash in” amount transacted by your customer.

We also believe that you should fill out a separate Part I on your CTR for your bank as an entity involved in the purchase of the cashier’s check. The CTR filing instructions clarify that banks must complete a separate Part I (Person Involved in Transaction) on each entity involved in a currency transaction. The purchase of a cashier’s check with cash is a currency transaction, in which your bank was involved. Consequently, we believe that you need to fill out a separate Part I with information about your bank.

For resources related to our guidance, please see:

  • FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements, Attachment C, pages 60–61 (“Item 25 Total cash in . . . a. Deposit(s) . . . d. Purchase of negotiable instrument(s) . . . Record the total cash in amount involved in the transaction(s) if that amount is greater than $10,000. Record the total amount on the “Total cash in” line and total or subtotals on whichever of line 25a through 25i best describe the transaction or aggregated transactions. . . . The total of the amounts recorded in fields 25a through 25z must equal the amount recorded in the Item 25 “Total cash in” field. The total cash in will be automatically computed in BSA E-Filing discrete FinCEN CTR from the entries in 25a through 25i and 25z. . . .”)
  • FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements, Attachment C, page 59 (“Item 21 Cash in amount: Enter the total cash in amount denominated in U.S. Dollars that was transacted by or for the person recorded in Item 4. This amount cannot be greater than the amount in Item 25 “Total cash in.” Record the account numbers of all accounts involved in the transaction(s) made by or for the person recorded in Item 4. . . .”)
  • FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements, Attachment C, page 49 (“For purposes of this FinCEN CTR, the terms below have the following meanings: Negotiable Instruments – All checks and drafts (including business, personal, bank, cashier’s and third-party), money orders, and promissory notes. . . .”)
  • FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements, Attachment C, page 54 (“Part I Person Involved in Transaction . . . Complete a separate Part I section on each individual or entity involved in the currency transaction(s).”)
  • FinCEN Regulations, 31 CFR 1010.100(bbb)(1) (With respect to a financial institution, “transaction” includes the “purchase or sale of any stock, bond, certificate of deposit, or other monetary instrument . . . or any other payment, transfer, or delivery by, through, or to a financial institution, by whatever means effected.”)