It was suspended almost immediately after its effective date due to the pandemic emergency declaration. It has not yet been reactivated or altered. Part of me thinks FinCEN is focusing on implementing the AML Act, and putting the CTR thing on the back burner. If there is to be any overhauling of the CTR/SAR filing rules as part of the AML Act effort, it would be sensible to leave the 2020 instructions in suspense until FinCEN decides what the AML Act changes, if any, will look like.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8