FinCEN Publishes Guidance on CTR Exemptions

On June 11, 2012, the Financial Crimes Enforcement Network (FinCEN) issued guidance to help financial institutions determine whether a customer or member is eligible for exemption from currency transaction reporting (CTR) requirements. The guidance is updated from a 2009 version to reflect the changes finalized in June 2012. The new rules address exemption eligibility for payroll customers.

The guidance provides examples and answers to commonly asked questions regarding CTR exemptions, including when a credit union should do a risk-based exemption for a member, how to address a business reorganization (such as from a sole proprietorship or DBA to a corporation or LLC), and what to do if a previously exempt business no longer qualifies for exemption.


Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News.