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To Self-Report or Not

Answered by: 

Question: 
During our routine internal audit, we noticed we had failed to file CTRs for one business because we thought they were exempt. Shall we self-report this error to my regulator?
Answer: 

You should definitely reach out to FinCEN to determine if back-filing is required. The interagency guidance does discuss that self-reporting may lessen the potential regulatory consent penalties.

First published on 07/11/2021

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