FYI - FinCEN is directing everyone to the latest CTR XML document. https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf.
NOTE: If the information entered into Part IV is the same for Part III check the box and complete Parts I
and II. Each FinCEN CTR filed may have up to 999 Part IIIâ€™s.
Prepare a separate Part III section for each transaction location involved in the currency transaction(s). Include
the amount transacted at each Part III location in Item 41 â€œCash-in amount for transaction locationâ€ and/or
Item 42 â€œCash-out amount for transaction location.â€ A transaction location (such as an office or ATM, for
example) may be owned or operated by the reporting financial institution required to file the FinCEN CTR or
by another financial institution involved in the transaction(s) through a shared branching or other contractual
Critical fields, denoted by an asterisk (*) in front of the item number, must be completed by providing the data
associated with that item. All other items must be completed when data are known but will be left blank when
data are unknown or do not apply.
I have auditors saying that if there is an ATM withdrawal done at Home Depot, we have to also include that as a location & fill in a Part III. Soooooo - do I now have to know what bank handles that ATM?