BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 7.1: Currency Transaction Reporting (cont.)

N/A

Yes Nc

Based on a review of incoming mail, if the institution is receiving currency deposits via mail, courier services, or internal deliveries, does the institution have procedures to ensure that CTRs are filed and proper records are maintained? Does the financial institution retain copies of CTRs for five years from the date of the report (31 CFR 1010.306(a)(2))?

NA

Y

Comments . Electronic Filing — The Bank discrete files CTRs through FinCEN's BSA eFiling System. Transaction aggregation — Transactions are aggregated by TIN. Error Notices — Request list responses indicate the Bank has not received any error notices from FinCEN. System Override — Tellers do not have the ability to override the aggregation system. Currency Deposits - Request list responses indicate that the Bank does not receive currency deposits via mail, courier service, or internal deliveries from customers.

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