Free reference 28 requirements
What are the BSA/AML dollar thresholds and filing deadlines?
Short answer
As of October 14, 2026, the currency transaction report (CTR) threshold is unchanged: more than $10,000 in currency in one transaction, filed with the Financial Crimes Enforcement Network (FinCEN) within 15 days after the day of the transaction under 31 CFR 1010.311. Bills to raise it to $30,000 (H.R. 1799 and S. 3017) have not passed Congress.
Banks file a suspicious activity report (SAR) at $5,000 (with a suspect or for Bank Secrecy Act (BSA) and money laundering activity), $25,000 regardless of suspect, and any amount for insider abuse; money services businesses (MSBs) at $2,000. A SAR is due 30 calendar days after initial detection, up to 60 days if no suspect is identified. Funds transfer records and the Travel Rule start at $3,000.
What is law today, and what is only pending
Some online summaries describe the CTR threshold as already raised to $30,000. It has not been. The eCFR text of 31 CFR 1010.311 (current through October 13, 2026) still reads "more than $10,000". Here is where each proposal stands.
-
$10,000
CTR, more than
15 days after the day of the transaction
-
$5,000
Bank SAR
30 days, 60 if no suspect
-
$25,000
Bank SAR, no suspect
Banking agency rules
-
$2,000
MSB SAR
30 days, no extension
-
$3,000
Travel Rule and transfer records
Per transfer
-
5 years
Record retention
CTR, SAR and BSA records
H.R. 1799, Financial Reporting Threshold Modernization Act
Status: Not law. Reported by the House Financial Services Committee (H. Rept. 119-556) and placed on the Union Calendar on March 19, 2026, after a 30-24 committee vote on January 22, 2026. No House floor vote in the bill status record.
Would change: CTR $10,000 to $30,000; Form 8300 (31 U.S.C. 5331) $10,000 to $30,000; SAR $5,000 to $10,000 and $2,000 to $3,000; MSB definition $1,000 to $3,000; all indexed to inflation every five years. Treasury would have 180 days after enactment to amend the regulations.
Status: Not law. Introduced October 20, 2025 and referred to the Senate Banking Committee; no further action in the bill status record.
Would change: CTR $10,000 to $30,000; Form 8300 $10,000 to $30,000; SAR $2,000 to $3,000 and $5,000 to $10,000; inflation updates every five years. Does not change the MSB definition.
FinCEN AML/CFT program proposed rule (RIN 1506-AB72)
Status: Proposed, not final. Announced April 7, 2026; published April 10, 2026 at 91 FR 18704; comments closed June 9, 2026. No final rule in the Federal Register as of October 14, 2026. FinCEN proposed an effective date 12 months after a final rule.
Would change: Program requirements (risk assessment, effectiveness standard, FinCEN role in supervision). It supersedes the July 2024 proposal. It does not propose new CTR or SAR dollar thresholds; the proposed text does not amend 31 CFR 1010.311 or the SAR rules.
Investment adviser AML/CFT program and SAR rule
Status: Final rule delayed. Effective date moved to January 1, 2028 (91 FR 36, January 2, 2026). Until then investment advisers have no SAR filing duty under 31 CFR Chapter X.
Would change: Adds registered investment advisers and exempt reporting advisers to the SAR and program rules from January 1, 2028.
FinCEN rulemaking on SAR or CTR thresholds in 2026
Status: None. A Federal Register search of all FinCEN documents published from January 1, 2025 to October 14, 2026 (42 documents) found no proposed or final rule changing a CTR or SAR dollar threshold. 2026 actions that do touch thresholds are temporary: the southwest border and Minnesota GTOs (rows above).
Would change: Nothing pending.
All 28 requirements
Citations are to Title 31, Chapter X of the Code of Federal Regulations (CFR) unless marked 12 CFR (banking agency SAR rules) or 26 CFR (Form 8300 timing). Open "Sources" on a row for the exact text checked. Two rows are temporary geographic targeting orders with end dates.
Click a column heading with ↕ to sort.
| Requirement | Applies to | Dollar threshold | Deadline | Form | Citation | Pending changes | Last verified |
|---|---|---|---|---|---|---|---|
| Currency transaction report (CTR) Currency transaction reports | Financial institutions other than casinos (banks, money services businesses, broker-dealers, mutual funds, futures commission merchants and introducing brokers, and others covered by the rule) | More than $10,000 in currency in one transaction | Within 15 days after the day of the transaction | FinCEN CTR (FinCEN Form 112) | 31 CFR 1010.311; 1010.306(a)(1) NotesCovers deposits, withdrawals, currency exchanges and other payments or transfers in currency. Keep a copy of each CTR for five years from the date of the report (31 CFR 1010.306(a)(2)). The threshold has not changed: the regulation text on eCFR still reads "more than $10,000". Sources (3)
| Not law. H.R. 1799 (Financial Reporting Threshold Modernization Act, reported by the House Financial Services Committee on March 19, 2026, no floor vote) and S. 3017 (STREAMLINE Act, introduced October 20, 2025, in committee) would each direct Treasury to raise this $10,000 threshold to $30,000 by regulation within 180 days of enactment. | |
| CTR aggregation of multiple transactions Currency transaction reports | Financial institutions other than casinos | Cash in or cash out totaling more than $10,000 in one business day, by or on behalf of any person, when the institution knows of the transactions | Same as the CTR: within 15 days after the day of the transaction | FinCEN CTR (FinCEN Form 112) | 31 CFR 1010.313 NotesCash in and cash out are totaled separately. Night, weekend and holiday deposits count as received on the next business day. All domestic branches count as one institution (1010.313(a)). Sources (1)
| Not law. H.R. 1799 (Financial Reporting Threshold Modernization Act, reported by the House Financial Services Committee on March 19, 2026, no floor vote) and S. 3017 (STREAMLINE Act, introduced October 20, 2025, in committee) would each direct Treasury to raise this $10,000 threshold to $30,000 by regulation within 180 days of enactment. | |
| Casino currency transaction report Currency transaction reports | Casinos and card clubs | More than $10,000 cash in or cash out | Within 15 days after the day of the transaction | FinCEN CTR (FinCEN Form 112) | 31 CFR 1021.311; 1010.306(a)(1) NotesThe rule lists cash-in items (chip purchases, front money, bets of currency, bills inserted into gaming devices) and cash-out items (chip redemptions, payments on bets, check cashing). Sources (2)
| Not law. H.R. 1799 (Financial Reporting Threshold Modernization Act, reported by the House Financial Services Committee on March 19, 2026, no floor vote) and S. 3017 (STREAMLINE Act, introduced October 20, 2025, in committee) would each direct Treasury to raise this $10,000 threshold to $30,000 by regulation within 180 days of enactment. | |
| CTR exemption: designating an exempt person Currency transaction reports | Banks | Non-listed businesses and payroll customers: transaction account open at least two months (or a documented risk-based assessment) and frequent currency transactions of more than $10,000 | File the designation within 30 calendar days after the first reportable transaction with the customer; review eligibility of non-listed businesses, payroll customers and other (b)(4) to (b)(7) exempt persons at least once a year | FinCEN Designation of Exempt Person (DOEP, FinCEN Form 110) | 31 CFR 1020.315(b), (c), (d) NotesExempt persons include other banks (domestic operations), government agencies and listed companies. The exemption does not cover a transaction an exempt person conducts as agent for another beneficial owner (1020.315(f)). Sources (4)
| None pending. H.R. 1799 and S. 3017 would raise the underlying CTR threshold if enacted. | |
| Bank suspicious activity report (SAR): BSA and money laundering transactions Suspicious activity reports | Banks (including savings associations and credit unions) | At least $5,000 in funds or other assets, when the bank knows, suspects or has reason to suspect the transaction involves illegal funds, is designed to evade the BSA, or has no apparent lawful purpose | 30 calendar days after initial detection; 30 more days (60 in total) if no suspect is identified; immediate phone call to law enforcement for violations that need immediate attention | FinCEN SAR (FinCEN Form 111) | 31 CFR 1020.320(a)(2), (b)(3) NotesNo SAR is required for a robbery or burglary reported to law enforcement (1020.320(c)). The federal banking agencies' own SAR rules (12 CFR 21.11, 208.62, 353.3, 748.1) add the insider-abuse, $5,000-with-suspect and $25,000 thresholds in the next rows. Sources (3)
| Not law. H.R. 1799 and S. 3017 would each direct the agencies to raise each $5,000 SAR threshold to $10,000 within 180 days of enactment. | |
| Bank SAR: insider abuse Suspicious activity reports | National banks and federal savings associations (OCC, 12 CFR 21.11 and 163.180); state member banks (12 CFR 208.62); FDIC-supervised institutions (12 CFR 353.3); federally insured credit unions (12 CFR 748.1) | Any amount, when the bank has a substantial basis for identifying a director, officer, employee, agent or other institution-affiliated party | 30 calendar days after initial detection (60 if no suspect identified) | FinCEN SAR (FinCEN Form 111) | 12 CFR 21.11(c)(1), (d) (OCC); parallel rules 12 CFR 208.62, 353.3, 748.1 NotesThis threshold comes from the banking agencies' rules, not 31 CFR Chapter X. The citation shown is the OCC rule; the Federal Reserve, FDIC and NCUA rules carry the same thresholds. Sources (2)
| None pending. | |
| Bank SAR: criminal violation with an identified suspect Suspicious activity reports | National banks and federal savings associations (OCC, 12 CFR 21.11 and 163.180); state member banks (12 CFR 208.62); FDIC-supervised institutions (12 CFR 353.3); federally insured credit unions (12 CFR 748.1) | $5,000 or more, when the bank has a substantial basis for identifying a possible suspect | 30 calendar days after initial detection | FinCEN SAR (FinCEN Form 111) | 12 CFR 21.11(c)(2) (OCC); parallel rules 12 CFR 208.62, 353.3, 748.1 NotesCovers known or suspected federal criminal violations against the bank or through it. Sources (1)
| Not law. H.R. 1799 and S. 3017 would each direct the agencies to raise each $5,000 SAR threshold to $10,000 within 180 days of enactment. | |
| Bank SAR: criminal violation regardless of suspect Suspicious activity reports | National banks and federal savings associations (OCC, 12 CFR 21.11 and 163.180); state member banks (12 CFR 208.62); FDIC-supervised institutions (12 CFR 353.3); federally insured credit unions (12 CFR 748.1) | $25,000 or more, even with no basis for identifying a suspect | 30 calendar days after initial detection; up to 60 if no suspect is identified | FinCEN SAR (FinCEN Form 111) | 12 CFR 21.11(c)(3) (OCC); parallel rules 12 CFR 208.62, 353.3, 748.1 NotesThe Federal Reserve (208.62), FDIC (353.3) and NCUA (748.1) rules use the same $25,000 figure. Sources (4)
| None pending. H.R. 1799 and S. 3017 change only the $5,000 and $2,000 SAR figures. | |
| Money services business SAR Suspicious activity reports | Money services businesses described in 31 CFR 1010.100(ff)(1) and (3) to (7): currency dealers and exchangers, issuers and sellers of money orders and traveler's checks, providers and sellers of prepaid access, money transmitters, and the U.S. Postal Service. Check cashers ((ff)(2)) are not on the list. | At least $2,000; $5,000 for a money order or traveler's check issuer when the review is of clearance records | 30 calendar days after initial detection (the MSB rule has no extra 30 days for an unidentified suspect) | FinCEN SAR (FinCEN Form 111) | 31 CFR 1022.320(a), (b)(3) NotesEach MSB in a transaction is responsible for reporting, but only one report is required if it contains all relevant facts (1022.320(a)(4)). Sources (4)
| Not law. H.R. 1799 and S. 3017 would raise the $2,000 threshold to $3,000 (and $5,000 to $10,000). | |
| Broker-dealer SAR Suspicious activity reports | Brokers or dealers in securities | At least $5,000 in funds or other assets | 30 calendar days after initial detection; 30 more days (60 in total) if no suspect is identified | FinCEN SAR (FinCEN Form 111) | 31 CFR 1023.320(a)(2), (b)(3) NotesSame suspicion standard as banks. Sources (2)
| Not law. H.R. 1799 and S. 3017 would each direct the agencies to raise each $5,000 SAR threshold to $10,000 within 180 days of enactment. | |
| Casino SAR Suspicious activity reports | Casinos and card clubs | At least $5,000 in funds or other assets | 30 calendar days after initial detection; 30 more days (60 in total) if no suspect is identified | FinCEN SAR (FinCEN Form 111) | 31 CFR 1021.320(a)(2), (b)(3) Sources (2)
| Not law. H.R. 1799 and S. 3017 would each direct the agencies to raise each $5,000 SAR threshold to $10,000 within 180 days of enactment. | |
| SAR: mutual funds, insurance companies, futures firms, loan or finance companies, housing GSEs Suspicious activity reports | Mutual funds (1024.320); insurance companies (1025.320); futures commission merchants and introducing brokers in commodities (1026.320); loan or finance companies, including non-bank residential mortgage lenders and originators (1029.320); housing government-sponsored enterprises (1030.320) | At least $5,000 in funds or other assets | 30 calendar days after initial detection; never more than 60 calendar days | FinCEN SAR (FinCEN Form 111) | 31 CFR 1024.320, 1025.320, 1026.320, 1029.320, 1030.320 NotesRegistered investment advisers are not on this list yet: their SAR rule is delayed to January 1, 2028 (see pending changes). Sources (5)
| Not law. H.R. 1799 and S. 3017 would each direct the agencies to raise each $5,000 SAR threshold to $10,000 within 180 days of enactment. Separately, FinCEN delayed the investment adviser AML/CFT program and SAR rule to January 1, 2028 (91 FR 36, January 2, 2026). | |
| Continuing activity SARs Suspicious activity reports Guidance (not a regulation) | All institutions covered by a SAR rule | No separate threshold | Not required. Institutions that choose to follow FinCEN's continuing-activity guidance: review a 90-day period after the prior SAR and file within 120 calendar days of it (initial SAR day 30, continuing SAR day 150) | FinCEN SAR (FinCEN Form 111) | FinCEN and federal banking agency SAR FAQs, October 9, 2025 (guidance, not a regulation) NotesThe FAQs say a separate post-SAR review is not required; risk-based monitoring may be relied on instead. The same FAQs say transactions near the $10,000 CTR threshold do not by themselves require a structuring SAR. Sources (3)
| None pending. | |
| SAR and supporting documentation retention Suspicious activity reports | All institutions covered by a SAR rule | Every SAR filed | Keep the SAR and supporting documentation for five years from the date of filing | Not applicable | 31 CFR 1020.320(d); 1022.320(c); parallel paragraphs in each SAR rule NotesSupporting documentation is deemed filed with the SAR and must be produced to FinCEN, law enforcement and the institution's BSA examiners on request. SARs are confidential (1020.320(e)). Sources (2)
| None pending. | |
| Funds transfer recordkeeping Recordkeeping | Banks (31 CFR 1020.410(a)) and nonbank financial institutions such as money transmitters (31 CFR 1010.410(e)) | $3,000 or more per funds transfer | Obtain the record at the time of the transfer; keep it five years (31 CFR 1010.430(d)) | Not applicable (records kept by the institution) | 31 CFR 1010.410(e); 1020.410(a) NotesThe originator's institution records name, address, amount, execution date, payment instructions and the beneficiary's institution, plus listed items received with the order. Sources (2)
| None pending. | |
| Travel Rule (pass originator and beneficiary information with the transfer) Recordkeeping | Transmittor's and intermediary financial institutions located in the United States, banks and nonbanks | $3,000 or more per transmittal of funds | Include the information in the transmittal order when it is sent to the next institution | Not applicable (data in the payment message) | 31 CFR 1010.410(f) NotesThe transmittor's institution includes name, account number, address, amount, execution date and the recipient's institution, among other items. FinCEN withdrew its unhosted-wallet proposal on October 6, 2026 (91 FR 63514), so no lower virtual-currency threshold is pending. Sources (2)
| None pending. | |
| Monetary instrument sales log Recordkeeping | Financial institutions selling bank checks or drafts, cashier's checks, money orders or traveler's checks for currency | $3,000 to $10,000 inclusive in currency; contemporaneous purchases totaling $3,000 or more count as one | Record at the time of sale; keep five years | Not applicable (records kept by the institution) | 31 CFR 1010.415 NotesPurchasers without a deposit account: record name, address, Social Security or alien identification number, date of birth and the instrument details, and verify identity. Sources (2)
| None pending. | |
| General BSA record retention Recordkeeping | All financial institutions with records required by 31 CFR Chapter X | Every required record | Five years, accessible within a reasonable period of time | Not applicable | 31 CFR 1010.430(d) NotesCTR copies (1010.306(a)(2)), SARs (1020.320(d)), Form 8300 copies (1010.330(e)(3)) and MSB registration copies (1022.380(b)(1)(iii)) carry their own five-year rules. Sources (1)
| None pending. | |
| Report of International Transportation of Currency or Monetary Instruments (CMIR) Cross-border and cash reports | Any person who physically transports, mails or ships currency or monetary instruments into or out of the United States, or receives an unreported shipment | More than $10,000 in aggregate at one time | At the time of entry, departure, mailing or shipping; recipients of an unreported shipment within 15 days after receipt | FinCEN Form 105 (filed with U.S. Customs and Border Protection) | 31 CFR 1010.340; 1010.306(b) NotesApplies to people and businesses, not only financial institutions. Sources (3)
| None pending. H.R. 1799 and S. 3017 do not change this threshold. | |
| Report of Foreign Bank and Financial Accounts (FBAR) Cross-border and cash reports | U.S. persons with a financial interest in, or signature or other authority over, financial accounts in a foreign country | Aggregate value of foreign financial accounts more than $10,000 at any time during the calendar year | April 15 of the following year, with an automatic extension to October 15 (no request needed) | FinCEN Form 114 (BSA E-Filing) | 31 CFR 1010.350; 1010.306(c); Pub. L. 114-41, sec. 2006(b)(11) NotesThe eCFR text of 31 CFR 1010.306(c) still reads "on or before June 30". The due date in practice is set by statute (Pub. L. 114-41, July 31, 2015): April 15 with a maximum six-month extension to October 15, which the IRS and FinCEN apply. Do not use the June 30 date. Sources (4)
| None pending. | |
| Form 8300: cash over $10,000 received in a trade or business Cross-border and cash reports | Any person who receives currency in the course of a trade or business (dealers, car sellers, real estate, professional firms). Not for amounts already reported on a CTR. | More than $10,000 in one transaction or two or more related transactions | By the 15th day after the cash is received; annual statement to each person named in a report by January 31 of the following year; keep a copy five years | Form 8300 (IRS/FinCEN) | 31 CFR 1010.330; 26 CFR 1.6050I-1(e), (f) NotesThe filer must verify the identity of the person paying the cash (1010.330(e)(2)). Sources (4)
| Not law. H.R. 1799 and S. 3017 would amend 31 U.S.C. 5331 to replace $10,000 with $30,000 and index it to inflation. | |
| Money services business definition thresholds Registration, information sharing and ownership | Non-bank businesses deciding whether they are an MSB | Currency dealer or exchanger, check casher, issuer or seller of traveler's checks or money orders: more than $1,000 for any person on any day. Money transmitter: no dollar threshold. Seller of prepaid access: more than $10,000 to any person in one day without preventive policies, or prepaid access usable before identity verification. | Not applicable (definition) | Not applicable | 31 CFR 1010.100(ff)(1) to (8) NotesBanks and SEC- or CFTC-regulated persons are excluded (1010.100(ff)(8)). A prepaid program excludes closed-loop access up to $2,000 a day and certain access capped at $1,000 (1010.100(ff)(4)(iii)). Sources (4)
| Not law. H.R. 1799 would raise each $1,000 figure to $3,000. S. 3017 does not change the MSB definition. | |
| MSB registration with FinCEN Registration, information sharing and ownership | Money services businesses (agents of another MSB and, unless they are agents, sellers of prepaid access are excepted) | Any business meeting the MSB definition | Initial registration within 180 days after the business is established; renew every two calendar years by December 31 of the year before the renewal period; re-register within 180 days after a state-law change of control, a transfer of more than 10% of voting power or equity, or a more than 50% increase in agents | Registration of Money Services Business (RMSB, FinCEN Form 107) | 31 CFR 1022.380(a), (b)(2) to (b)(4) NotesKeep the agent list and a copy of the registration for five years. Sources (5)
| None pending. | |
| Section 314(a) information request Registration, information sharing and ownership | Financial institutions that receive FinCEN 314(a) requests (banks, broker-dealers and others) | Any match to a named subject: current accounts, accounts in the preceding 12 months, and transactions in the preceding 6 months | Report positive matches within the time frame in FinCEN's request; FinCEN's fact sheet gives two weeks from the posting date. Do not reply if there is no match. | FinCEN secure portal response | 31 CFR 1010.520(b)(3) NotesThe regulation does not fix the number of days; the two-week window comes from FinCEN's 314(a) fact sheet (updated September 29, 2026). Keep the existence of a request confidential. Sources (3)
| None pending. | |
| Beneficial ownership of legal entity customers (CDD rule) Registration, information sharing and ownership | Covered financial institutions: banks, broker-dealers, mutual funds, futures commission merchants and introducing brokers (31 CFR 1010.605(e)(1)) | Each individual owning 25% or more of the equity, plus one individual with significant responsibility to control the entity | At the first account opening; afterwards only when facts call earlier information into question or risk-based procedures require it (FinCEN exceptive relief FIN-2026-R001, February 13, 2026) | Certification form (Appendix A to 31 CFR 1010.230) or equivalent | 31 CFR 1010.230(b), (d); FIN-2026-R001 NotesThe relief removes the duty to re-identify owners at every new account; the 25% and control prongs are unchanged. This rule is separate from Corporate Transparency Act reporting to FinCEN (next row). Sources (3)
| None pending. | |
| Corporate Transparency Act beneficial ownership information (BOI) report Registration, information sharing and ownership | Only entities formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction. Companies formed in the United States are exempt. | Not a dollar threshold; U.S. person beneficial owners are not reported | Within 30 calendar days after notice that the foreign entity's registration to do business is effective | BOI report (BOI E-Filing System) | 31 CFR 1010.380(a)(1)(i), (c)(1); final rule 91 FR 52508 (August 14, 2026) NotesFinCEN's March 26, 2025 interim final rule (90 FR 13688) exempted domestic companies; the final rule effective August 14, 2026 made that permanent and also exempted U.S. person company applicants. Sources (3)
| None pending. | |
| Southwest border Geographic Targeting Order (GTO): lowered CTR threshold Temporary orders Temporary order (ends March 1, 2027) | Money services businesses in listed ZIP codes of Cameron, El Paso, Hidalgo, Maverick and Webb counties, Texas, and Bernalillo, Dona Ana and San Juan counties, New Mexico (except MSBs covered by a court injunction) | Currency transactions of $1,000 or more, but not more than $10,000 | CTR within 30 days after the transaction; order runs September 3, 2026 to March 1, 2027 | FinCEN CTR (FinCEN Form 112), e-filed | GTO, 91 FR 56776 (September 4, 2026), issued under 31 U.S.C. 5326 NotesA GTO lasts at most 180 days unless renewed. The MSB SAR threshold stays at $2,000. Sources (3)
| Ends March 1, 2027 unless FinCEN renews it. | |
| Minnesota Geographic Targeting Order: international funds transfers Temporary orders Temporary order (ends February 6, 2027) | Banks and money transmitters with a branch, subsidiary or office in Hennepin or Ramsey County, Minnesota | Funds transfers of $3,000 or more (those already subject to recordkeeping) where the originator gives an address in the two counties and the beneficiary or its institution is outside the United States, with listed exceptions | Report by the end of the month after the month of the transfer, through FinCEN's FI Portal; order runs August 11, 2026 to February 6, 2027 | CSV submission on the FinCEN FI Portal | GTO, 91 FR 51588 (August 11, 2026), issued under 31 U.S.C. 5326 NotesExceptions include publicly traded originators and originators that are themselves financial institutions with AML program duties. Sources (3)
| Ends February 6, 2027 unless FinCEN renews it. |
These thresholds feed the controls in the AML/BSA Risk Assessment Template (Fintech Edition): its control inventory covers CTR filing, SAR decisioning and deadline tracking, 314(a) searches and Travel Rule data capture. Incident notice clocks are on the incident notification deadlines page.
Not included, and why
- Status of Treasury's Anti-Money Laundering Act of 2020 threshold reviews (sections 6204 and 6205). No FinCEN or Treasury primary document on the outcome was found; H.R. 1799 would require the reviews to be conducted, which suggests they are not complete, but that is an inference.
- Any NDAA provision on CTR or SAR thresholds. No enacted provision was found. What is verified is that the eCFR text of 31 CFR 1010.311 still reads "more than $10,000" (point-in-time 2026-10-13), so no change has taken effect.
- Casino multiple-transaction aggregation (31 CFR 1021.313). Not fetched and checked in this pass; the casino CTR row cites 1021.311 only.
- Investment adviser SAR dollar threshold. The delayed rule text (89 FR 72156) was not fetched; the page states only the delayed effective date.
◆ How to use this
Read the row, then read the statute.
- Find your institution type in "Applies to". A bank in a fintech partnership, or a fintech that is also a registered MSB, can owe several of these at once.
- Read the threshold literally: "more than $10,000" (CTR, CMIR, Form 8300) means $10,000.01 or more; "at least $5,000" and "$3,000 or more" include the round number.
- SAR clocks run in calendar days from the date of initial detection of facts that may be a basis for filing, not from the transaction date or the alert date.
- Check the "Pending changes" column before you cite a number. Bills and proposed rules there are not law until enacted and implemented.
- Open "Sources" on any row to see the exact regulation text it was checked against, and read the full section before relying on it.
Methodology
Each row was checked against the regulation text fetched from the eCFR point-in-time API (title 31 up to date as of 2026-10-13; title 12 and title 26 the same date), the Federal Register, govinfo bill status files, and FinCEN or IRS pages. The verbatim field of each source is the exact text checked. Last verified October 14, 2026. Each dollar threshold in the table is checked by our build against the quoted source text for its row. Requirements we could not confirm in primary text are listed under "Not included".
Not legal advice
This is a reference summary for risk and compliance teams, not legal advice. Laws change and how they apply depends on your facts. Confirm each obligation against the cited text and with counsel before you rely on a deadline.
◆ FAQ
Common questions.
Has the CTR threshold changed?
No. As of October 14, 2026 the regulation still requires a CTR for more than $10,000 in currency in one transaction (31 CFR 1010.311), filed within 15 days after the day of the transaction. Two bills would raise it to $30,000. H.R. 1799, Financial Reporting Threshold Modernization Act: Not law. Reported by the House Financial Services Committee (H. Rept. 119-556) and placed on the Union Calendar on March 19, 2026, after a 30-24 committee vote on January 22, 2026. No House floor vote in the bill status record. S. 3017, STREAMLINE Act: Not law. Introduced October 20, 2025 and referred to the Senate Banking Committee; no further action in the bill status record. Each bill gives Treasury 180 days after enactment to amend the regulation, so $10,000 applies until that happens. The one current exception is temporary: money services businesses in listed ZIP codes of Cameron, El Paso, Hidalgo, Maverick and Webb counties, Texas, and Bernalillo, Dona Ana and San Juan counties, New Mexico must report currency transactions of $1,000 or more, but not more than $10,000 under a geographic targeting order (GTO) that ends March 1, 2027.
When is a SAR due?
Banks, broker-dealers, casinos and most other filers: 30 calendar days after initial detection; 30 more days (60 in total) if no suspect is identified; immediate phone call to law enforcement for violations that need immediate attention (31 CFR 1020.320(b)(3) and the parallel rules). MSBs: 30 calendar days after initial detection (the MSB rule has no extra 30 days for an unidentified suspect) (31 CFR 1022.320(b)(3)). Continuing activity: not required. Institutions that choose to follow FinCEN's continuing-activity guidance: review a 90-day period after the prior SAR and file within 120 calendar days of it (initial SAR day 30, continuing SAR day 150), per FinCEN's October 9, 2025 SAR FAQs. Keep each SAR and its supporting documentation five years from filing.
Do fintechs file SARs, or does the bank?
It depends on what the fintech is. A fintech registered with FinCEN as an MSB, such as a money transmitter, has its own SAR duty under 31 CFR 1022.320 (at least $2,000, 30 calendar days after initial detection), and in a bank partnership that duty runs alongside the bank's. In a banking-as-a-service (BaaS) program where the fintech is not itself a BSA financial institution, the SAR is the bank's to file, because the bank rule covers any transaction "if it is conducted or attempted by, at, or through the bank" (31 CFR 1020.320(a)(2)). The fintech can monitor and draft for the bank under contract, but in a July 25, 2024 joint statement the Federal Reserve, Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) wrote that "the third party may perform certain regulatory compliance functions such as monitoring and reporting suspicious activity, customer identification programs, customer due diligence, and sanctions compliance on behalf of the bank. Regardless of whether the functions are shared between the bank and the third party, the bank remains responsible for failure to comply with applicable requirements." Institutions may file a joint SAR (31 CFR 1020.320(e)), and among MSBs one report with all relevant facts covers each MSB involved (31 CFR 1022.320(a)(4)).
What triggers the Travel Rule?
A transmittal of funds of $3,000 or more. Transmittor's and intermediary financial institutions located in the United States, banks and nonbanks must include the originator and transfer information in the transmittal order when it is sent (31 CFR 1010.410(f)). The same $3,000 figure triggers funds transfer recordkeeping for banks (31 CFR 1020.410(a)) and nonbank financial institutions such as money transmitters (31 CFR 1010.410(e)).
Is the FBAR due June 30 or April 15?
April 15, with an automatic extension to October 15. The eCFR text of 31 CFR 1010.306(c) still reads "on or before June 30". The due date in practice is set by statute (Pub. L. 114-41, July 31, 2015): April 15 with a maximum six-month extension to October 15, which the IRS and FinCEN apply. Do not use the June 30 date.
Do US companies still file beneficial ownership information (BOI) reports?
No. Only entities formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction. Companies formed in the United States are exempt. FinCEN's March 26, 2025 interim final rule (90 FR 13688) exempted domestic companies; the final rule effective August 14, 2026 made that permanent and also exempted U.S. person company applicants. Banks' own beneficial ownership collection under the customer due diligence (CDD) rule is separate and still applies at 25%.
◆ Sources
Primary sources.
eCFR sections, Federal Register documents, govinfo bill records and FinCEN and IRS pages behind each row, pending item and answer.
- 31 CFR 1010.311
- 31 CFR 1010.306(a)
- FinCEN, BSA forms and filing requirements
- 31 CFR 1010.313
- 31 CFR 1021.311
- 31 CFR 1020.315(c)(1)
- 31 CFR 1020.320(a)(2)
- 12 CFR 21.11(c)(1)
- 12 CFR 208.62 (Federal Reserve)
- 12 CFR 353.3 (FDIC)
- 12 CFR 748.1 (NCUA)
- 31 CFR 1022.320(a)(1)
- 31 CFR 1023.320(a)(2)
- 31 CFR 1021.320(a)(2)
- 31 CFR 1024.320 (mutual funds)
- 31 CFR 1025.320 (insurance companies)
- 31 CFR 1026.320 (FCMs and IBs)
- 31 CFR 1029.320 (loan or finance companies)
- 31 CFR 1030.320 (housing GSEs)
- SAR FAQs, Question 2
- 31 CFR 1010.410(e)
- 31 CFR 1020.410(a)
- Withdrawal of the convertible virtual currency transactions proposal, 91 FR 63514 (Oct 6, 2026)
- 31 CFR 1010.415(a)
- 31 CFR 1010.430(d)
- 31 CFR 1010.340(a)
- Pub. L. 114-41, sec. 2006(b)(11)
- IRS, Report of Foreign Bank and Financial Accounts (FBAR)
- FinCEN, Report Foreign Bank and Financial Accounts
- 31 CFR 1010.330(a)(1)(i)
- 26 CFR 1.6050I-1(e)(1)
- 31 CFR 1010.100(ff)(1)
- 31 CFR 1022.380(b)(3)
- FinCEN, MSB registration
- 31 CFR 1010.520(b)(3)(ii)
- FinCEN 314(a) fact sheet
- 31 CFR 1010.230(d)
- 31 CFR 1010.605(e)(1)
- FinCEN exceptive relief FIN-2026-R001
- 31 CFR 1010.380(a)(1)(i)
- Final rule, 91 FR 52508
- GTO, Covered Transaction
- Minnesota GTO, summary
- Bill status (govinfo), latest action
- H.R. 1799 as reported, sec. 2(a)(1)
- Bill status (govinfo)
- S. 3017 as introduced, sec. 2(b)
- 91 FR 18704, dates
- FinCEN news release, April 7, 2026
- 91 FR 36
- Federal Register API, FinCEN documents since 2025-01-01
- Federal Reserve, FDIC and OCC, Joint Statement on Banks' Arrangements with Third Parties to Deliver Bank Deposit Products and Services (July 25, 2024)
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