Financial institutions are often the point at which illegitimately earned money enters the financial system. This process is known as the placement stage and is the first of three stages of money laundering. As such, financial institutions are required to comply with anti-money laundering (AML) regulations and provide financial information to identify and discourage money laundering and financial crime.
Currency transaction reports (CTR) are among the most widely used and effective AML reports. They play a crucial role in detecting and preventing money laundering, terrorist financing, and other illicit activities.
The rules governing CTRs are facing their first serious challenge in decades. Lawmakers have introduced bills to raise the $10,000 threshold for the first time since it was set in 1970, and FinCEN continues to use geographic targeting orders to lower that threshold in specific high-risk areas. This guide covers what CTRs are, who must file them, and the regulatory changes compliance teams should be watching.
Key Highlights
- CTRs must be filed with FinCEN for cash transactions exceeding $10,000 in a single business day, a threshold that has not changed since 1970.
- Banks, credit unions, casinos and card clubs, money service businesses, and securities brokers and dealers are all subject to CTR filing obligations, subject to certain exemptions.
- Structuring, splitting transactions to fall under the reporting threshold, is illegal, and institutions must file a SAR if they suspect it.
- FinCEN’s FY2024 Year in Review reported approximately 20.6 million CTRs filed in a single year, making it the highest-volume BSA report by far.
- A FinCEN Geographic Targeting Order in effect through September 2, 2026 lowers the CTR threshold to $1,000 for certain MSBs along the Arizona, California, New Mexico, and Texas border.
- Pending federal legislation, the STREAMLINE Act and the Financial Reporting Threshold Modernization Act, would raise the standard CTR threshold from $10,000 to $30,000, but neither has been enacted.
What Are Currency Transaction Reports (CTRs)?
CTRs are reports that financial institutions must file with the Financial Crimes Enforcement Network (FinCEN), detailing transactions involving cash or other currency exceeding $10,000. For example, whenever a bank customer deposits, withdraws, or transfers more than $10,000 in one day, or makes multiple transactions amounting to $10,000, a bank must send a CTR to FinCEN.
The CTR form requires information such as the account number and verified customer identity information, which is one reason banks and financial services businesses are required to collect identifying information from customers in the first place.
Banks must also submit a CTR when a customer requests a transaction over the threshold but then changes their mind. For example, if they initially ask to deposit $11,000 but then decide to deposit $9,500 or abandon the transaction, the bank will submit a CTR and a Suspicious Activity Report (SAR).
It is illegal for customers to attempt to circumvent reporting by splitting the money into multiple transactions with amounts smaller than the reporting threshold. This practice is called structuring, and banks are obligated to file a SAR if they suspect a customer is attempting to structure their transactions in this way.
CTRs are also, by a wide margin, the highest-volume report financial institutions file with FinCEN. According to FinCEN’s Year in Review for fiscal year 2024, institutions filed approximately 20.6 million CTRs that year, compared to roughly 20.5 million Suspicious Activity Reports and far smaller totals for other Bank Secrecy Act (BSA) reports.
A Brief History of CTR Requirements
CTRs were first introduced in the Bank Secrecy Act of 1970 (BSA). Prior to the BSA, law enforcement agencies relied on banks to voluntarily report suspicious activity. They often declined to do so to protect the privacy of their customers.
The BSA introduced the concept of CTRs as a means to monitor large cash transactions, which were often associated with illegal activities such as drug trafficking, organized crime, and tax evasion. Initially, banks were only required to report transactions involving cash or negotiable instruments of more than $10,000. Over time, the scope of reportable transactions expanded to include additional types of businesses, institutions, and instruments.
As financial crimes evolved and became more sophisticated, so did the CTR requirements. Over the years, amendments and new regulations were introduced to strengthen CTRs and adapt to changing threats and technologies. For instance, the USA PATRIOT Act of 2001 expanded the definition of financial institutions subject to CTR reporting and introduced new anti-money laundering requirements.
CTRs were once paper forms that had to be filled in and sent to FinCEN. Today, electronic filing makes it easier for businesses to submit CTRs. FinCEN operates the Bank Secrecy Act E-Filing System, which streamlines the submission process.
For additional information on the history of compliance legislation and requirements, view our timeline of key BSA/AML regulations.
Who Is Required to Submit Currency Transaction Reports?
A wide range of financial businesses are subject to CTR reporting obligations, including:
- Banks and credit unions must report currency transactions exceeding $10,000, whether they involve deposits, withdrawals, or the exchange of currency.
- Casinos and card clubs must file CTRs for cash transactions over $10,000 related to gaming activities, such as the purchase of chips or the redemption of winnings.
- Money service businesses (MSBs), which include money transmitters, check cashers, and currency exchanges, are required to report transactions involving the transfer or exchange of currency over $10,000.
- Securities brokers and dealers that trade in stocks, bonds, and other securities must file CTRs for cash transactions exceeding the threshold, including the purchase or sale of securities.
The $10,000 threshold can also drop for specific institutions and regions. A FinCEN Geographic Targeting Order currently in effect through September 2, 2026 requires MSBs in specified ZIP codes across Arizona, California, New Mexico, and Texas near the southwest border to file CTRs for cash transactions of $1,000 or more, well below the standard threshold. FinCEN has renewed similar orders repeatedly since 2025 and has signaled it intends to keep targeting MSBs in border regions, so businesses operating in or near those areas should confirm whether the order applies to them.
However, while most large currency transactions must be reported, there are exceptions and exemptions that apply to specific transactions and customers, such as:
- Transactions between financial institutions: Currency transactions between banks or other financial institutions are generally exempt from CTR reporting.
- Transactions involving government entities: Transactions conducted by federal, state, or local government agencies or certain international organizations may be exempt from CTR requirements.
- Established business relationships: Financial institutions may be allowed to exempt certain customers from CTR reporting if they have an established business relationship and meet specific criteria, such as being publicly traded or having a history of regular large currency transactions.
Proposed Changes to CTR Reporting Thresholds
The $10,000 CTR threshold has not changed since Congress set it in 1970, and lawmakers are now pushing to update it. In October 2025, Senate Banking Committee Chairman Tim Scott and Senator John Kennedy introduced the STREAMLINE Act (S. 3017), which would raise the CTR threshold from $10,000 to $30,000 and require the Treasury to adjust it for inflation every five years. It would also raise related SAR thresholds. A companion bill in the House, the Financial Reporting Threshold Modernization Act (H.R. 1799), proposes the same $30,000 CTR threshold. Both bills have drawn support from industry groups including the American Bankers Association and America’s Credit Unions, who argue that the current threshold (worth roughly $80,000 in today’s dollars, had it kept pace with inflation) now captures far more routine transactions than regulators originally intended.
Neither bill has been enacted as of this writing, so the $10,000 threshold remains in effect for now. Compliance teams should still track this legislation closely: a change of this size would affect CTR volume, staffing needs, and how transaction monitoring systems are configured across the industry.
Beyond CTRs: Building a Complete AML Compliance Program
CTRs are just one of the many AML obligations that banks, money services businesses, and other financial institutions must comply with, and that obligation is likely to keep evolving rather than staying fixed. An AML compliance software, like Alessa, can streamline many of these obligatory processes. The Alessa regulatory reporting module is able to automate tedious reporting tasks, allowing for a greater volume of reports to be filed with greater accuracy, whatever the reporting threshold happens to be at the time.
Alessa provides a wide range of AML services to banks and credit unions, casinos, money services businesses, the FinTech industry and more, including:
- Identity verification and KYC
- Watchlist and sanctions screening
- Transaction monitoring
- Automated regulatory reporting for SARs, CTRs and STRs
Schedule a demo today to learn how Alessa can help your company streamline its AML and regulatory reporting processes.
