If the individual owner operates under multiple DBAs, complete a separate Part I section for each different DBA involved in the transactions.If the individual owner is operating under a DBA name, ensure such name appears in Item 8 “Alternate name,” and that the rest of Part I (other than Items 4-6, 7 and 17 identifying the individual owner) is completed with reference to the DBA name.If the individual owner is doing business in his or her own name, ensure that the rest of Part I is completed so it reflects the individual owner’s information.Complete a single Part I “Person Involved in Transaction” section with the individual owner’s name in Items 4 through 6, gender in Item 7, and date of birth in Item 17.§ 1010.100(mm)), FinCEN makes clear that “a sole proprietorship is not a separate legal person from its individual owner.” Therefore, when preparing a CTR FinCEN Form 112 on transactions involving a sole proprietorship, a financial institution should heed the following FinCEN instructions:
![currency transaction report currency transaction report](https://s3.amazonaws.com/images.federalregister.gov/EN11JA06.003/original.gif)
In the FinCEN Ruling, FinCEN defines a sole proprietorship as “a business in which one person, operating in his or her own personal capacity, owns all of the business’s assets and is responsible for all of the business’s liabilities.” Consistent with the definition of “person” under the Bank Secrecy Act’s implementing regulations (31 C.F.R. Filing of CTR FinCEN Form 112 for a Sole Proprietorship The FinCEN Ruling addresses reporting obligations when filing using the current CTR FinCEN Form 112. 1, 2020, for BSA E-Filing batch filers), replaces and rescinds two previous FinCEN rulings: FIN-2006-R003 and FIN-2008-R001, which were based on the now obsolete FinCEN Form 104. The FinCEN Ruling, which becomes effective Ap(Sept. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published administrative ruling FIN-2020-R001, to clarify requirements of financial institutions reporting on currency transactions involving sole proprietorships and legal entities operating under a “doing business as” (DBA) name (“FinCEN Ruling”). With your support, BPC can continue to fund important research like this by combining the best ideas from both parties to promote health, security, and opportunity for all Americans.On Feb. Today, there is not a single new car you could buy in cash without triggering a report.Īre Banks Reporting State Governments to Uncle Sam?Īcceleration in Suspicious Activity Reporting Warrants Another LookĬasting a Wide Net: The Expanding Reach of Anti-Money Laundering Laws For example, back then you could have bought a brand new Cadillac in cash and not even come close to triggering a report.
![currency transaction report currency transaction report](https://www.marefa.org/images/thumb/1/1e/Currency_Transaction_Report%2C_March_2011_revision.pdf/page2-180px-Currency_Transaction_Report%2C_March_2011_revision.pdf.jpg)
To highlight how out of touch the current threshold is with the original intent of the requirement, we have assembled a list of items that one could have bought in cash without triggering a report when the limit was originally set in 1972.
![currency transaction report currency transaction report](https://community.dynamics.com/cfs-file/__key/communityserver-discussions-components-files/33/3034.post.png)
The Bipartisan Policy Center believes that now is the time for policymakers to revise the CTR reporting limit. In fact, as of today, Saint Patrick’s Day, the typical American family has earned enough that if they deposited or withdrew their salary in cash, it would trigger a CTR. More than four decades later, that $10,000 figure remains unchanged, despite substantial inflation and economic growth.
![currency transaction report currency transaction report](https://www.pdffiller.com/preview/1/671/1671989.png)
This threshold to trigger a Currency Transaction Report (CTR) was a substantial sum of money at the time?more than an entire year’s worth of income for the typical American household. In the early 1970s the federal government instituted a new anti-money laundering provision, requiring banks to report to the Treasury Department any cash transaction involving more than $10,000. Why Do 1970s Prices Dictate Anti-Money Laundering Rules? | Bipartisan Policy Center Skip to main content Bipartisan Policy Center logo