IBA Compliance Connection

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Are we required to file currency transaction reports (CTRs) for our own cash order shipments from Thillens, since they use their own account to satisfy our cash order requests?

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Yes, we recommend filing CTRs for cash shipments received from Thillens as directed in a recent administrative ruling from FinCEN.

While the IBA argued in its request for relief that CTR filing requirements are unnecessary for a bank’s own cash shipments executed by Thillens, FinCEN unfortunately denied our request for relief. The ruling is somewhat helpful in that it includes updated filing instructions that should ease the use of FinCEN’s e-filing system when completing CTRs for cash shipments fulfilled by Thillens.

Additionally, FinCEN’s ruling notes that it has “provided exceptive relief from the obligation to back file CTRs to those Banks that have requested relief from FinCEN.” Your bank may wish to seek an exception from the obligation to back file if you have not done so already. For that purpose, we are including a sample letter to FinCEN that a member of our Compliance Division Advisory Committee received from Thillens for their use. If you choose to use it as a template, we recommend reviewing it carefully, as not all information may pertain to your bank.

For resources related to our guidance, please see: