FinCEN Form 104 (Eff. 03-2011)
Page 3
Suspicious Transactions
This Currency Transaction Report (CTR) should NOT be
filed for suspicious transactions involving $10,000 or less
in currency OR to note that a transaction of more than
$10,000 is suspicious. Any suspicious or unusual activity
should be reported by a financial institution in the manner
prescribed by its appropriate federal regulator or BSA
examiner. (See the instructions for Item 37). If a transaction
is suspicious and in excess of $10,000 in currency, then
both a CTR and the appropriate Suspicious Activity Report
form must be filed.
In situations involving suspicious transactions requiring
immediate attention, such as when a reportable transaction
is ongoing, the fianacial institution shall immediately notify
,
by telephone, appropriate law enforcement and regulatory
authorities in addition to filing a timely suspicious activity
report.
General Instructions
Who Must File. Each financial institution (other than a
casino, which instead must file FinCEN Form 103, and the
U.S. Postal Service for which there are separate rules) must
file FinCEN Form 104 (CTR) for each deposit, withdrawal,
exchange of currency
, or other payment or transfer, by,
through, or to the financial institution which involves a
transaction in currency of more than $10,000. Multiple
transactions must be treated as a single transaction if the
financial institution has knowledge that (1) they are by or
on behalf of the same person, and (2) they result in either
currency received (Cash In) or currency disbursed (Cash
Out) by the financial institution totaling more than $10,000
during any one business day. For a bank, a business day is
the day on which transactions are routinely posted to
customers’ accounts, as normally communicated to
depository customers. For all other financial institutions,
a business day is a calendar day.
Generally, financial institutions are defined as banks, other
types of depository institutions, brokers or dealers in
securities, money transmitters, currency exchangers, check
cashers, and issuers and sellers of money orders and traveler’s
checks. Should you have questions, see the definitions in
31 CFR Chapter X.
When and Where To File. This form should be e-filed
through the Bank Secrecy Act E-filing System. Go to
http: //bsaefiling.fincen.treas.gov/index.jsp to register.
This form is also available for download on the Financial
Crimes Enforcement Network’s Web site at www.fincen.gov,
or may be ordered by calling the IRS Forms Distribution
Center at (800) 829-3676. File this CTR by the 15th
calendar day after the day of the transaction with the:
Enterprise Computing Center - Detroit
ATTN: CTR
P.O. Box 33604
Detroit, MI 48232-5604
Keep a copy of each CTR for five years from the date filed.
A financial institution may apply to file the CTRs
electronically. To obtain an application to file
electronically, contact the Bank Secrecy Act E-filing
System. Go to http: //bsaefiling.fincen.treas.gov/
main.html to register or contact the
BSA E-Filing Help
Desk at 1-866-346-9478 (select option # 6) or via email
at
BSAEFilingHelp@fincen.gov
Identification Requirements. All individuals (except a
employees of armored car services) conducting a reportable
transaction(s) for themselves or for another person, must be
identified by means of an official
document(s).
Acceptable forms of identification include
driver’s license, military and military/dependent
identification cards, passport, state issued identification
card, cedular card (foreign), non-resident alien identification
cards, or any other identification document
or documents, which contain name and preferably address
and a photograph and are normally acceptable by financial
institutions as a means of identification when cashing checks
for persons other than established customers.
Acceptable identification information obtained previously
and maintained in the financial institution’s records may be
used. For example, if documents verifying an individual’s
identity were examined and recorded on a signature card
when an account was opened, the financial institution may
rely on that information. In completing the CTR, the
financial institution must indicate on the form the method,
type, and number of the identification. Statements such as
“known customer” or “signature card on file” are not
sufficient for form completion.
Penalties. Civil and criminal penalties are provided for
failure to file a CTR or to supply information or for filing a
false or fraudulent CTR. See 31 U.S.C. 5321, 5322 and
5324.
For purposes of this CTR, the terms below have the
following meanings:
Currency. The coin and paper money of the United States
or any other country, which is circulated and customarily
used and accepted as money.
Person. An individual, corporation, partnership, trust or
estate, joint stock company, association, syndicate, joint
venture or other unincorporated organization or group.
Organization. Entity other than an individual.
Transaction in Currency. The physical transfer of currency
from one person to another. This does not include a transfer
of funds by means of bank check, bank draft, wire transfer or
other written order that does not involve the physical transfer
of currency.
Negotiable Instruments. All checks and drafts (including
business, personal, bank, cashier’s and third-party), money
orders, and promissory notes. For purposes of this CTR,
all traveler’s checks shall also be considered negotiable
instruments whether or not they are in bearer form.
Foreign exchange rate. If foreign currency is a part of a
currency transaction that requires the completion of a
CTR, use the exchange rate in effect for the business day
of the transaction to compute the amount, in US dollars,
to enter in item 26/27. The source of the exchange rate that
is used will be determined by the reporting institution.
Specific Instructions
Because of the limited space on the front and back of the
CTR, it may be necessary to submit additional information
on attached sheets. Submit this additional information on
plain paper attached to the CTR. Be sure to put the
individual’
s or entity’s name and identifying number (items
2, 3, 4, and 6 of the CTR) on any additional sheets so that
if it becomes separated, it may be associated with the CTR.
Item 1a. Amends Prior Report. If this CTR is being
filed because it amends a report filed previously
, check
Item 1a. Complete the form in its entirety (Part I, II,
and III) and include the amended information. Do not
attach a copy of the original.
Multiple Persons. If this transaction is being conducted
by more than one person or on behalf of more than one
person, check Item 1b. Enter information in Part I for one
of the persons and provide information on any other
persons on the back of the CTR.
Item 1c. Multiple
Transactions. If the financial institution
has knowledge that there are multiple transactions, check
Item 1c.
PART I - Person(s) Involved in Transaction(s)
Section A must be completed. If an individual conducts a
transaction on his own behalf, complete Section A and
leave Section “B” BLANK. If an individual conducts a
transaction on his own behalf and on behalf of another
person(s), complete Section “A” for each person and leave
Section “B” BLANK. If an individual conducts a
transaction on behalf of another person(s), complete Section
“B” for the individual conducting the transaction, and
complete Section “A” for each person on whose behalf the
transaction is conducted of whom the financial institution
has knowledge.
Section A. Person(s) on Whose Behalf Transaction(s)
Is Conducted. See instructions above.
Items 2, 3, and 4. Individual/Organization Name. If
the person on whose behalf the transaction(s) is conducted
is an individual, put his/her last name in Item 2, first name
in Item 3, and middle initial in Item 4. If there is no
middle initial, leave item 4 BLANK. If the transaction is
conducted on behalf of an entity, enter the name in Item 2
and leave Items 3 and 4 BLANK.
Item 5. Doing Business As (DBA). If the financial
institution has knowledge of a separate “doing business
as” name, enter it in Item 5. For example, if Smith
Enterprise is doing business as MJ’s Pizza, enter “MJ’s
Pizza” in item 5.
Item 6. SSN or EIN. Enter the Social Security Number
(SSN) or Individual Taxpayer Identification Number (ITIN)
or Employer Identification Number (EIN) of the person or
entity identified in Item 2. If none, leave blank.
Items 7, 9, 10, 11, and 12. Address. Enter the permanent
address including ZIP Code of the person identified in Item
2. Use the U.S. Postal Service’s two letter state abbreviation
code. A P. O. Box should not be used by itself, and may
only be used if there is no street address. If a P. O. Box is
used, the name of the apartment or suite number, road or
route number where the person resides must also be provided.
If the address is outside the U.S., provide the street address,
city, province or state, postal code (if known), and the two
letter country code. For country code list go to
www.fincen.gov/reg_bsaforms.html or telephone 800-949-
2732 and select option number 5. If U.S., leave item 12
blank.
Item 8. Date of Birth. Enter the date of birth. Eight
numerals must be inserted for each date. The first two will
reflect the month, the second two the day, and the last four
the year. A zero (0) should precede any single digit number.
For example, if an individual’s birth date is April 3 1948,
Item 8 should read 04 03 1948.
Item 13.
Occupation, profession, or business. If known,
identify the occupation, profession or business that best
describes the individual or entity in Part I (e.g., attorney,
car dealer, carpenter, doctor, farmer, plumber, truck driver,
etc.). Do not use nondescript terms such as businessman,
merchant, store owner (unless store’s name is provided), or
self employed. If unemployed, or retired are used enter the
regular or former occupation if known.
Item 14. If an Individual, Describe Method Used To
Verify Identity. If an individual conducts the transaction(s)
on his/her own behalf, his/her identity must be verified by
examination of an acceptable document (see General
Instructions). For example, check box a if a driver’s license
is used to verify an individual’s identity, and enter the state
that issued the license and the number in items e and f. If
the transaction is conducted by an individual on behalf of
another individual not present, or on behalf of an entity,
check box “14d” “Other” and enter “NA” on the line
provided.