Financial institutions must submit FinCEN Form 112 for any physical cash transaction (deposit, withdrawal, exchange, or transfer) that exceeds $10,000 within a single business day.
Syndicate Legal Advisory Services provides nationwide legal document preparation services for broker-dealer firms required to prepare Currency Transaction Reports (CTRs) under the Bank Secrecy Act and related regulations (31 CFR § 1023.310 et seq. and 31 CFR § 1010.311 et seq.). We prepare FinCEN Form 112 and related supporting materials based on the transaction details, customer identification information, and specific instructions you provide.
Documents Commonly Prepared
We prepare a full range of documents associated with a Currency Transaction Report, including but not limited to:
- FinCEN Form 112 (CTR): Completion of the Currency Transaction Report form, including filer information, person conducting the transaction, person on whose behalf the transaction is conducted, transaction details, and related sections, based on the facts and data you supply.
- Aggregated Transaction Reports: Preparation of CTRs reflecting multiple related transactions that aggregate to more than $10,000 in a single business day, based on the transaction data you provide.
- Related Supporting Materials: Organization of exhibits or attachments incorporating client-supplied identification documents, transaction records, or other materials referenced in the report.
- Internal Documentation: Formatting of internal summaries or supporting notes for the firm’s records, based on information you provide (note: retention of filed CTRs and supporting documentation is the firm’s responsibility).
Documents are prepared for use in connection with electronic filings through the FinCEN BSA E-Filing System (subject to the information you provide). CTRs are generally required for each deposit, withdrawal, exchange of currency, or other payment or transfer by, through, or to the broker-dealer which involves a transaction in currency of more than $10,000 (with aggregation of multiple transactions by or on behalf of the same person in a single business day); filings are due within 15 calendar days of the transaction date; identification of the person conducting the transaction is required; clients remain fully responsible for determining reportability (including aggregation and any applicable exemptions), the accuracy of the content, timely electronic filing via BSA E-Filing, retention of copies for five years, and compliance with all Bank Secrecy Act, FinCEN, SEC, and FINRA requirements.
