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CTR Filing - US Mint Coins

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Question: 
One of the operational units within our bank offers customers the opportunity to purchase gold and/or silver coins and have them delivered to their place of residence via the US Postal Service. In the case of US Mint coins , such as $50 Buffalo gold coins, are these considered "currency" for purposes of CTR filing, and if so, what amount should be indicated on the CTR; the face value of the coins (ie. 201 coins @ $50 = $10,050), or the intrinsic value of the coins (ie. 201 1 oz. gold coins @ $900 ea = $180,900)? Can you direct me to any regs that address this question?
Answer: 

Review the definition of Currency at 31 CFR 103.11(h):

(h) Currency. The coin and paper money of the United States or of any other country that is designated as legal tender and that circulates and is customarily used and accepted as a medium of exchange in the country of issuance [Emphasis added]. Currency includes U.S. silver certificates, U.S. notes and Federal Reserve notes. Currency also includes official foreign bank notes that are customarily used and accepted as a medium of exchange in a foreign country.

Certain mint issues would, I think, fit the definition. However, I don't think you could say that $50 gold pieces, although legal tender, are customarily used as a medium of exchange; therefore, I don't think you would consider them currency for the purposes of a CTR.

First published on BankersOnline.com 6/08/09

First published on 06/08/2009

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