BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Transaction Testing Checklist 7.3: Currency Transaction Reports

Reviewed/Total/%

Sample Date

1 September 2015 2 October 2015 3 November 2015

5/10/50% 3/6/50% 4/7/57% 12/23/52%

Total

Currency Transaction Reports

1

2

3

Was the CTR properly completed in accordance with IRS instructions? 31 CFR 1010.311(b)(1) Was the CTR consistent with the type and nature of business or occupation of the customer and the transaction amounts? 31 CFR 1010.311(b)(1) Was the CTR e-filed within 15 calendar days after the date of the transaction? 31 CFR 1010.311(b)(1) If the currency transactions appeared suspicious, was a Suspicious Activity Report filed?

Y

ei)

01

Y

Y

Y

y

y

y

NA NA NA

Comments: 31 CFR 1010.311(b)(1) requires financial institutions to file properly completed CTRs. Additional filing instructions and information are included in FinCEN CTR Electronic Filing Requirements Attachment C —Electronic Filing Instructions and FinCEN CTR FAQs. Apparent technical violations were noted for 2 of 12 (16%) CTRs reviewed for the sample period. Refer to the CTR Worksheet for specific details. Recommendation — It is recommended that FinCEN be contacted to determine if the CTRs with errors should be re-filed.

6 6