The Currency and Foreign Transactions Reporting Act of 1970, commonly known as the Bank Secrecy Act, introduced the modern CTR (check out my last blog post to explore how the “BSA” got its name). This “new” Part 102, however, was exactly the same as the 1952 Title 31, Part 102 regulation-nothing changed! 1970 – Currency and Foreign Transactions Reporting Act In an odd, inexplicable twist, there was a notice of an “amendment” to the Title 31, Part 102 regulation published in the Federal Register on August 4, 1959.
![currency transaction report currency transaction report](https://community.dynamics.com/resized-image/__size/640x480/__key/communityserver-discussions-components-files/33/Currency-exchange.png)
1959 – Treasury “Reintroduced” the Mandatory Reporting Threshold of $10,000? The result was mandatory reporting of all single cash transactions of $2,500 or more in denominations of $100 or higher, or $10,000 or more in any denominations, and discretionary reporting of unusual cash transactions in any amount. Monthly reports were now required for “transactions involving $2,500 or more of United States currency in denominations of $100 or higher” and “transactions involving $10,000 or more of United States currency in any denominations” with the interesting addition of required reporting of “transactions involving any amount in any denominations, which in the judgment of the financial institution exceed those commensurate with customary conduct of the business, industry, or profession of the person or organization concerned.”
![currency transaction report currency transaction report](https://data.formsbank.com/pdf_docs_html/358/3584/358497/page_1_thumb_big.png)
In 1952, the large cash transaction reporting regulation – still under the authority of the TWEA and still in Part 102 of Title 31 – was amended so that the $10,000 threshold reporting was mandatory, rather than discretionary.
![currency transaction report currency transaction report](https://www.pdffiller.com/preview/21/169/21169137.png)
1952 – A Mandatory Reporting Threshold of $10,000 is Instituted The result of the 1945 TWEA regulation was that financial institutions had to file a monthly report of any cash transaction over $1,000 in denominations of $50 or higher, or any cash transaction over $10,000, unless the institution deemed the transactions as commensurate with the expected, legitimate conduct of that customer. While the regulation – Part 102 of Title 31 – required financial institutions to file monthly reports concerning these deposits and withdrawals, it was at the discretion of institutions to judge if the activity was unusual for their customer, and to file, or not file, the transaction report accordingly. On June 5, 1945, as World War II was drawing to a close, the Trading With the Enemy Act was used as the statutory authority for a regulation that required financial institutions to report single cash transactions of $1,000 or more, in denominations of $50 or higher, or transactions involving $10,000 or more, in any denomination-sort of. 1945 – A Discretionary Reporting Threshold of $10,000 is Established Notwithstanding its original, limited purpose, TWEA remains in force today and, with the International Emergency Economic Powers Act (IEEPA), forms the backbone for OFAC’s economic sanctions programs. The Trading with the Enemy Act (TWEA) of 1917 was passed to prevent and restrict trade with American enemies at times of war. Those events start over 100 years ago … 1917 – Trading with the Enemy Act (TWEA) Introduced Let’s explore the timeline of events that led to the CTR threshold, and the impact each event had on that threshold. But how and why was this transaction reporting threshold created? How did the Treasury Department first settle on $10,000 as the reporting threshold? The $10,000 cash transaction threshold, first established in 1972, is still in place today, almost fifty years later. With FinCEN reporting increases in BSA report filings year over year, it is likely that over 16 million Currency Transaction Reports, or CTRs, were filed in 2019, each one reporting one or more cash transactions made by or on behalf of any person aggregating more than $10,000.