Dear Board of Directors,
The Financial Crimes Enforcement Network (FinCEN) recently released an educational pamphlet, “Notice to Customers: A CTR Reference Guide.” This pamphlet explains the CTR reporting requirement to members who may not be familiar with the credit union’s obligations under the Bank Secrecy Act (BSA).
This pamphlet does not alter a credit union’s BSA reporting requirements. The pamphlet explains that large currency transactions are not illegal, and that credit unions are required to obtain information from their members when conducting such transactions. The pamphlet also explains what constitutes structuring and explains that if a member attempts to structure transactions there are potential civil and criminal consequences.
(opens new window). FinCEN is exploring the possibility of printing a supply of these pamphlets so credit unions can order them from FinCEN in the future.
If you have any questions regarding this educational pamphlet, please contact your district examiner, regional office, or state supervisory authority.
Michael E. Fryzel