Skip to content
BOL Conferences
Thread Options
#1994350 - 02/06/15 10:21 PM Foreign Currency CTR
KTW327 Offline
100 Club
KTW327
Joined: Mar 2011
Posts: 183
In the trees
Customer comes in an deposits a CTR reportable amount of cash. The cash is intended for the exchange of foreign currency, but the the foreign currency must be ordered. A few days pass, the foreign currency is received. Now we have questions.

Only if the foreign currency amount is over $10,000 USD is it reportable on the CTR, correct?

This was an exchange, but it took about a week to complete. Do we still mark it as an exchange? Or would it be "other"?

Do we put the USD amount in 27 (appropriate box) and then ALSO put the foreign amount in box 28 with the currency code?

Return to Top
BSA/AML/CIP/OFAC Forum
#1994402 - 02/08/15 04:31 PM Re: Foreign Currency CTR KTW327
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You're wanting to report what "really" happened, a currency exchange. While that's commendable, these transactions took place on two different banking days and the CTR requires you to choose a single date. I suggest you report the first as a deposit on the day it took place and the second as a withdrawal on the day it took place.

Only the second transaction involves non U.S. currency. If its conversion value exceeds $10,000, U.S. then it's reportable as you describe.

I'll defer to others with more relevant experience, but suggest it might be a bit odd for someone to effectively buy currency with currency in reportable amounts.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1994536 - 02/09/15 06:06 PM Re: Foreign Currency CTR KTW327
KTW327 Offline
100 Club
KTW327
Joined: Mar 2011
Posts: 183
In the trees
Thanks for the advice. I agree that this could be suspicious and we will definitely look into that.

I am still confused on how we would actually report it. Would we list the amount of cash out in USD in 27 and then list the foreign equivalent in 28? Or is it JUST box 27 or JUST box 28?

Return to Top
#1994956 - 02/10/15 07:08 PM Re: Foreign Currency CTR KTW327
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Both 27 (denominated in U.S. dollars) and 28 (denominated in the foreign currency). In each case, round partial units up to the next full unit ($15,195.32 becomes 15196 in item 27 and €12,395.27 becomes 12396 in item 28).
Last edited by John Burnett; 02/10/15 07:14 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z