Think of the CTR as an extra report you may have to file with FinCEN in addition to a SAR if the transaction involves $10,000.01 or more in a single day. If you operate a cryptocurrency exchange, and a customer attempts to sell more than $10,000-worth of bitcoin in a single day, you will also need to file a cryptocurrency CTR. You might need to file a SAR if your customer cannot produce proper identification, or if you catch multiple customers using the same social security number.įor a CTR, the only criteria is the amount - $10,000.01 or more in transactions in a single day.Īdditionally, for crypto, this works both ways. That will require you to file a Currency Transaction Report.Īdditionally, if a customer executes multiple transactions over the course of a day that add up to more than $10,000 (a process known as “structuring,” which qualifies as suspicious activity in its own right), a CTR will need to be filed.Īs we said above and in our blog post on the topic, SAR filing is required based on a wide range of criteria. What does this look like in the context of a cryptocurrency business? Let’s say you’re a crypto ATM operator and a customer purchases bitcoin from one of your machines with over $10,000 in cash. What is a Currency Transaction Report (CTR)?Ī CTR is a report to be filed electronically with FinCEN when a customer deposits, withdraws, exchanges, or otherwise transfers over $10,000 cash with a financial institution (i.e. What they are, what will trigger them, how they should be filed (and how often), as well as a continued emphasis on the importance of strong reporting procedures in surveillance and monitoring. Today we’re talking about Currency Transaction Reports (CTRs). We’re continuing our series of cryptocompliance 101 posts to help cryptocurrency business owners understand the regulatory landscape, its nuances, and what steps need to be taken to strengthen their compliance. One of them is the Currency Transaction Report. There are other reports you may need to file in addition to SARs on occasion. We covered SARs in a previous blog post you’re encouraged to check the post out later if you’ve missed it, but the gist is that SARs are catch-all reports governing a wide range of suspicious transaction criteria.ĭoes that mean as long as you file SARs to report suspicious activity you’re good to go? SARs are required to be filed with FinCEN by the Bank Secrecy Act (BSA) of 1970. The most common report related to dubious transactions you will need to file is the Suspicious Activity Report (SAR). This is because there are reports regulators require your BSA Compliance Officer to file based on transaction size alone. Usually, red flags are based on things like transaction frequency and customer information, but every institution involved in the exchange of currency, crypto or otherwise, will have red flags based on certain dollar amounts. That’s why we encourage new business owners in the space to reach out to BitAML for a free consultation to help them understand their unique profile. Meticulously detailed red flags are absolutely critical to robust bitcoin compliance. These red flags must be unique to your institution’s business model and risk profile, and every employee must be trained to screen for suspicious activity. In a previous post, we talked about the importance of a strong surveillance and monitoring procedure designed to catch suspicious activity and protect cryptocurrency money services businesses (MSBs) and money transmitters from financial crime, like money laundering.Īs we discussed, good surveillance and monitoring practices are built upon a series of “red flags,” or custom alert routines that allow your employees to spot transactions that might not be on the up-and-up. Do cryptocurrency businesses ever need to file Currency Transaction Reports? Every AML program should include a policy and procedure for CTR filing.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |