Is a financial institution required to file form 105 – International Transportation of Currency or Monetary Instruments? We are a local community bank and do not have foreign branches nor do we deal in foreign currency. Occasionally, we will get a foreign check (usually Canadian) for deposit that we clear through our correspondent bank, but per policy we do not accept foreign currency.

I attended a BSA seminar that stated that banks are not required to complete form 105, that the form is required to be completed by Customs. Is this true?

It's my understanding that banks are required to complete FinCEN Form 105 whenever they send or receive $10,000 in currency or other monetary instruments outside the United States.

That is my understanding too

Refer to the instructions section of the 105 form for exact clarification and to decide if you are required to do so or not.

here is the link

Fincen 105 Form and Instructions

The "Who Must File" section of the instructions states clearly, under "Exceptions" to the filing requirement, that "banks" are given a blanket exemption from filing. The definition of "bank" is fairly broad and includes most types of regulated financial institutions other than MSBs.