FinCEN has issued an administrative ruling to the IBA, denying the IBA’s request for relief from currency transaction report (CTR) filing requirements for a bank’s own cash shipments executed by Thillens armored car service. However, FinCEN’s ruling notes that it has “provided exceptive relief from the obligation to back file CTRs to those Banks that have requested relief from FinCEN.” Consequently, banks may wish to seek an exemption from the obligation to back file CTRs for past transactions if they have not done so already. Additionally, FinCEN’s ruling contains updated filing instructions for completing CTRs for Thillens shipments that should ease the use of FinCEN’s e-filing system for CTRs going forward.
Read the Administrative Ruling
Read the IBA Request for Relief