If US currency is exchanged for foreign currency and the US currency amount is over $10,000, is a CTR required?
Most definitely. A currency exchange is two-sided. That is, there is cash in and cash out. In most cases, the “outs” and “ins” are equal.
If the exchange is the only transaction being reported, record the dollar amount of U.S. currency being exchanged in the cash in (item 26) or cash out (item 27) lines, whichever applies. Then record the U.S. dollar equivalent of the foreign currency in the other of these two items. If the customer brings in foreign currency and obtains U.S. currency from you, the U.S. currency is listed in item 27 and the U.S. equivalent in foreign currency in item 26. In simple exchanges, these amounts are probably the same.
Then, put the amount of foreign currency in either item 26a or 27a (depending on whether the foreign currency was received by the bank or sold by the bank). For example, record 11000 in item 26 if the customer brought in €11,000 (euros). Then, record the two-letter foreign country code for the foreign currency in item 29 (for euros, enter “EE”). One side or the other of a currency exchange of less than $10,000 might have to be reported, when aggregated with other cash activity by or on behalf of the same person.
First published on BankersOnline.com 10/05/09
First published on 10/05/2009
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