Large and Shady Bank Transfers Are Reported
Did you know that if you get a $9,999 transfer from your parents to help you out on a down payment, the bank won’t be required by the Bank Secrecy Act to report the deposit on a Currency Transaction Report (CTR); if they give you $10,000 then they are required to report it? The purpose behind these, and other reports mandated by the BSA, reports is to help the Feds find out if someone is laundering money.
Now, if there are a whole bunch of transfers for $5,000, the bank could always opt to report the transfers if they suspect something is fishy. This way they can report the deposits even if they don’t individually exceed $10,000 themselves.
The FinCEN Form 104 Currency Transaction Report (CTR) is the report that is filed when there is a transaction (deposit, withdrawal, currency conversion, etc) over $10,000 or over. The FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments (CMIR) is the report that is filed when someone transports or causes to be transported into or out of the United States.
Now, if the bank suspect something is up (i.e. a law is being broken), they’ll file a Treasury Department Form 90-22.47 and an OCC Form 8010-9, 8010-1 Suspicious Activity Report (SAR).
Whew!
So, what does this mean for the average Joe? Nothing really… it’s just a big of useful trivia. 
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There are 13 comments, add your thoughts now!
I knew that there was a reason that I haven’t closed my unused online banking accounts…heheh…
If only there was somebody to fill them up with $9000 deposits…I don’t suppose that if they were made to different accounts that the form would get filed.
Clarification, these reports are filed only when the transaction involves actual paper cash. Wire, ACH, checks, etc.. are not included.
yeah, I learned this from watching the Sopranos.
I wonder if my bank did this to me when I deposited $15,000 into my account the other day. I got it from Amex for 0% credit card arbitrage.
The reporting amount can be changed daily. Sometimes it as low as two thousand dollars. the ten thousand dollar figure is a smoke screen to more or less catch people who are repeatedly trying to stay under that figure to avoid detection.
Hmm. I wonder if there is another rule that governs wire transfers? What if someone’s parents is paying for their daughter’s house and wanted to transfer the money to her bank account first?
Jason is correct, this is only for paper cash transactions. Also, its actually any cash transactions *over* $10000 meaning that you can withdraw $10k without a CTR, but if you take $10000.01 then a CTR needs to be filed.
Also, if a teller tells you what the threshold is for filing a CTR they may be guilty of violating the Bank Secrecy Act and could be subject to some serious criminal penalties. Its illegal to structure cash transactions in order to avoid a CTR. For example, if you have $11k burning a hole in your pocket and deposit $5000 today and $6000 tomorrow, you are now a criminal.
Sorry, I work in a bank and this is just so fascinating to me. Yes, I’m a nerd.
[...] is useless information. Jim from Blueprint for Financial Prosperity shares some trivia about how large bank transactions are reported to the feds. All transactions over $10,000 are reported, which theoretically includes 0% balance transfers from [...]
Tom,
Having a CTR or a SAR report filed for you doesn’t mean you’re in any type of trouble or are a criminal. Its just their way of red-flagging it for a closer look to make sure you’re legit. For example, a vending machine business owner depositing $15k in cash once a month isn’t a criminal, nothing is wrong with it. They’ll just check it more closely to make sure its not from criminal activity and isn’t being laundered.
I used to work at a retail bank, by far the worst job I’ve ever had.
I’m not suggesting that. But to structure your deposits in order to avoid a CTR is a crime. And I do work at a retail bank currently. Not such a bad gig if you ask me.
Structuring is also not a crime, just another thing you could be written up for to be flagged (with a SAR instead of a CTR). Its not a crime to make multiple deposits instead of one big one, but it is something tellers look out for to write a SAR for. The SAR basically exists so that people making multiple deposits are written up the same way people making big deposits are. No two are a crime.
I just made a payment of $14,130.00 to my mortgage company
by using a personal check (no cash). Is this something that they
would report to the IRS?
Does anyone know what the IRS/FinCEN does after they receive a report?
I just deposited a large sum of money, and am wondering if they’ll come after me at work or something with all these questions.
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