Skip to content
RiskTemplates · The Daily Brief Thursday, October 22, 2026
Wire DOJ WHIP Whistleblower Rewards Put a 120-Day Clock on Internal Investigations OCT 20

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.

Last verified:

Download CSV JSON

How to use this Sources

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.

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.

S. 3017, STREAMLINE Act

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.

Bank Secrecy Act dollar thresholds and filing deadlines, last verified October 14, 2026
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)
Notes

Covers 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)
  • 31 CFR 1010.311
    "Each financial institution other than a casino shall file a report of each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000, except as otherwise provided in this section."
  • 31 CFR 1010.306(a)
    "(a)(1) A report required by § 1010.311 or § 1021.311, shall be filed by the financial institution within 15 days following the day on which the reportable transaction occurred. (2) A copy of each report filed pursuant to §§ 1010.311, 1010.313, 1020.315, 1021.311 and 1021.313, shall be retained by the financial institution for a period of five years from the date of the report."
  • FinCEN, BSA forms and filing requirements
    "FinCEN CTR Form 112"
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
Notes

Cash 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)
  • 31 CFR 1010.313
    "(b) Multiple transactions. In the case of financial institutions other than casinos, for purposes of the transactions in currency reporting requirements in this chapter, multiple currency transactions shall be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day (or in the case of the U.S. Postal Service, any one day). Deposits made at night or over a weekend or holiday shall be treated as if received on the next business day following the deposit."
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)
Notes

The 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)
  • 31 CFR 1021.311
    "Each casino shall file a report of each transaction in currency, involving either cash in or cash out, of more than $10,000."
  • 31 CFR 1010.306(a)(1)
    "(a)(1) A report required by § 1010.311 or § 1021.311, shall be filed by the financial institution within 15 days following the day on which the reportable transaction occurred."
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)
Notes

Exempt 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)
  • 31 CFR 1020.315(c)(1)
    "(c) Designation of certain exempt persons —(1) General. Except as provided in paragraph (c)(2) of this section, a bank must designate an exempt person by filing FinCEN Form 110. Such designation must occur by the close of the 30-calendar day period beginning after the day of the first reportable transaction in currency with that person sought to be exempted from reporting under the terms of this section."
  • 31 CFR 1020.315(b)(6)
    "(i) Maintains a transaction account, as defined in paragraph (e)(9) of this section, at the bank for at least two months, except as provided in paragraph (c)(2)(ii) of this section; (ii) Frequently engages in transactions in currency with the bank in excess of $10,000;"
  • 31 CFR 1020.315(d)
    "(d) Annual review. At least once each year, a bank must review the eligibility of an exempt person described in paragraphs (b)(4) to (7) of this section to determine whether such person remains eligible for an exemption."
  • FinCEN, BSA forms and filing requirements
    "FinCEN DOEP Form 110"
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)
Notes

No 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)
  • 31 CFR 1020.320(a)(2)
    "(2) A transaction requires reporting under the terms of this section if it is conducted or attempted by, at, or through the bank, it involves or aggregates at least $5,000 in funds or other assets, and the bank knows, suspects, or has reason to suspect that:"
  • 31 CFR 1020.320(b)(3)
    "(3) When to file. A bank is required to file a SAR no later than 30 calendar days after the date of initial detection by the bank of facts that may constitute a basis for filing a SAR. If no suspect was identified on the date of the detection of the incident requiring the filing, a bank may delay filing a SAR for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction."
  • FinCEN, BSA forms and filing requirements
    "FinCEN SAR Form 111"
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
Notes

This 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)
  • 12 CFR 21.11(c)(1)
    "(1) Insider abuse involving any amount. Whenever the national bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank, where the bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations, or that the bank was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying one of its directors, officers, employees, agents or other institution-affiliated parties as having committed or aided in the commission of a criminal act, regardless of the amount involved in the violation."
  • 12 CFR 21.11(d)
    "(d) Time for reporting. A national bank is required to file a SAR no later than 30 calendar days after the date of the initial detection of facts that may constitute a basis for filing a SAR. If no suspect was identified on the date of detection of the incident requiring the filing, a national bank may delay filing a SAR for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction."
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
Notes

Covers known or suspected federal criminal violations against the bank or through it.

Sources (1)
  • 12 CFR 21.11(c)(2)
    "(2) Violations aggregating $5,000 or more where a suspect can be identified. Whenever the national bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank and involving or aggregating $5,000 or more in funds or other assets where the bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations or that it was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying a possible suspect or group of suspects."
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
Notes

The Federal Reserve (208.62), FDIC (353.3) and NCUA (748.1) rules use the same $25,000 figure.

Sources (4)
  • 12 CFR 21.11(c)(3)
    "(3) Violations aggregating $25,000 or more regardless of potential suspects. Whenever the national bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank and involving or aggregating $25,000 or more in funds or other assets"
  • 12 CFR 208.62 (Federal Reserve)
    "(3) Violations aggregating $25,000 or more regardless of a potential suspect."
  • 12 CFR 353.3 (FDIC)
    "(3) Transactions aggregating $25,000 or more regardless of potential suspects."
  • 12 CFR 748.1 (NCUA)
    "(iii) Transactions aggregating $25,000 or more regardless of potential suspects."
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)
Notes

Each 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)
  • 31 CFR 1022.320(a)(1)
    "(a) General. (1) Every money services business described in § 1010.100(ff)(1), (3), (4), (5), (6), and (7) of this chapter, shall file with the Treasury Department"
  • 31 CFR 1022.320(a)(2)
    "(2) A transaction requires reporting under the terms of this section if it is conducted or attempted by, at, or through a money services business, involves or aggregates funds or other assets of at least $2,000 (except as provided in paragraph (a)(3) of this section)"
  • 31 CFR 1022.320(a)(3)
    "(3) To the extent that the identification of transactions required to be reported is derived from a review of clearance records or other similar records of money orders or traveler's checks that have been sold or processed, an issuer of money orders or traveler's checks shall only be required to report a transaction or pattern of transactions that involves or aggregates funds or other assets of at least $5,000."
  • 31 CFR 1022.320(b)(3)
    "(3) When to file. A money services business subject to this section is required to file each SAR no later than 30 calendar days after the date of the initial detection by the money services business of facts that may constitute a basis for filing a SAR under this section."
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)
Notes

Same suspicion standard as banks.

Sources (2)
  • 31 CFR 1023.320(a)(2)
    "conducted or attempted by, at, or through a broker-dealer, it involves or aggregates funds or other assets of at least $5,000"
  • 31 CFR 1023.320(b)(3)
    "(3) When to file. A SAR shall be filed no later than 30 calendar days after the date of the initial detection by the reporting broker-dealer of facts that may constitute a basis for filing a SAR under this section. If no suspect is identified on the date of such initial detection, a broker-dealer may delay filing a SAR for an additional 30 calendar days to identify a suspect, but in no case shall reporting be delayed more than 60 calendar days after the date of such initial detection."
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)
  • 31 CFR 1021.320(a)(2)
    "conducted or attempted by, at, or through a casino, and involves or aggregates at least $5,000 in funds or other assets"
  • 31 CFR 1021.320(b)(3)
    "(3) When to file. A SAR shall be filed no later than 30 calendar days after the date of the initial detection by the casino of facts that may constitute a basis for filing a SAR under this section. If no suspect is identified on the date of such initial detection, a casino may delay filing a SAR for an additional 30 calendar days to identify a suspect, but in no case shall reporting be delayed more than 60 calendar days after the date of such initial detection."
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
Notes

Registered 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)
Notes

The 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)
  • SAR FAQs, Question 2
    "A financial institution is not required to conduct a separate review—manual or otherwise—of a customer or account following the filing of a SAR to determine whether suspicious activity has continued."
  • SAR FAQs, Question 3
    "Subsequent FinCEN guidance advised financial institutions to file SARs for continuing activity after a 90-day period with the filing deadline being 120 calendar days after the date of the previously related SAR filing."
  • SAR FAQs, Question 3 timeline
    "• Day 0: detection of facts that may constitute a basis for filing a SAR • Day 30: filing of initial SAR • Day 120: end of 90-day period • Day 150: filing of a SAR for continued suspicious activity"
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
Notes

Supporting 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)
  • 31 CFR 1020.320(d)
    "(d) Retention of records. A bank shall maintain a copy of any SAR filed and the original or business record equivalent of any supporting documentation for a period of five years from the date of filing the SAR."
  • 31 CFR 1022.320(c)
    "(c) Retention of records. A money services business shall maintain a copy of any SAR filed and the original or business record equivalent of any supporting documentation for a period of five years from the date of filing the SAR."
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)
Notes

The 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)
  • 31 CFR 1010.410(e)
    "(e) Nonbank financial institutions. Each agent, agency, branch, or office located within the United States of a financial institution other than a bank is subject to the requirements of this paragraph (e) with respect to a transmittal of funds in the amount of $3,000 or more:"
  • 31 CFR 1020.410(a)
    "(a) Each agent, agency, branch, or office located within the United States of a bank is subject to the requirements of this paragraph (a) with respect to a funds transfer in the amount of $3,000 or more,"
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)
Notes

The 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
Notes

Purchasers 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)
  • 31 CFR 1010.415(a)
    "(a) No financial institution may issue or sell a bank check or draft, cashier's check, money order or traveler's check for $3,000 or more in currency unless it maintains records of the following information, which must be obtained for each issuance or sale of one or more of these instruments to any individual purchaser which involves currency in amounts of $3,000-$10,000 inclusive:"
  • 31 CFR 1010.415(b), (c)
    "(b) Contemporaneous purchases of the same or different types of instruments totaling $3,000 or more shall be treated as one purchase. Multiple purchases during one business day totaling $3,000 or more shall be treated as one purchase if an individual employee, director, officer, or partner of the financial institution has knowledge that these purchases have occurred. (c) Records required to be kept shall be retained by the financial institution for a period of five years"
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)
Notes

CTR 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)
  • 31 CFR 1010.430(d)
    "(d) All records that are required to be retained by this chapter shall be retained for a period of five years."
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)
Notes

Applies to people and businesses, not only financial institutions.

Sources (3)
  • 31 CFR 1010.340(a)
    "(a) Each person who physically transports, mails, or ships, or causes to be physically transported, mailed, or shipped, or attempts to physically transport, mail or ship, or attempts to cause to be physically transported, mailed or shipped, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time"
  • 31 CFR 1010.306(b)
    "(b)(1) A report required by § 1010.340(a) shall be filed at the time of entry into the United States or at the time of departure, mailing or shipping from the United States, unless otherwise specified by the Commissioner of Customs and Border Protection. (2) A report required by § 1010.340(b) shall be filed within 15 days after receipt of the currency or other monetary instruments."
  • FinCEN, BSA forms and filing requirements
    "CMIR 105"
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)
Notes

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.

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)
Notes

The filer must verify the identity of the person paying the cash (1010.330(e)(2)).

Sources (4)
  • 31 CFR 1010.330(a)(1)(i)
    "who, in the course of a trade or business in which such person is engaged, receives currency in excess of $10,000 in 1 transaction (or 2 or more related transactions) shall, except as otherwise provided, make a report of information with respect to the receipt of currency."
  • 31 CFR 1010.330(e)(3)
    "(3) Retention of reports. A person required to make a report under this section must keep a copy of each report filed for five years from the date of filing."
  • 26 CFR 1.6050I-1(e)(1)
    "(1) Time of reporting. The reports required by this section must be filed in accordance with the Form 8300 instructions and related publications by the 15th day after the date the cash is received."
  • 26 CFR 1.6050I-1(f)(3)
    "(3) When statement is to be furnished. Statements required under this paragraph (f) must be furnished to an identified person on or before January 31 of the year following the calendar year in which the cash is received."
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)
Notes

Banks 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)
  • 31 CFR 1010.100(ff)(1)
    "(1) Dealer in foreign exchange. A person that accepts the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more countries in exchange for the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more other countries in an amount greater than $1,000 for any other person on any day in one or more transactions, whether or not for same-day delivery."
  • 31 CFR 1010.100(ff)(2)(i)
    "(2) Check casher —(i) In general. A person that accepts checks (as defined in the Uniform Commercial Code), or monetary instruments (as defined at § 1010.100(dd)(1)(ii), (iii), (iv), and (v)) in return for currency or a combination of currency and other monetary instruments or other instruments, in an amount greater than $1,000 for any person on any day in one or more transactions."
  • 31 CFR 1010.100(ff)(5)(i)
    "(5) Money transmitter —(i) In general. (A) A person that provides money transmission services. The term “money transmission services” means the acceptance of currency, funds, or other value that substitutes for currency from one person and the transmission of currency, funds, or other value that substitutes for currency to another location or person by any means."
  • 31 CFR 1010.100(ff)(7)
    "(7) Seller of prepaid access. Any person that receives funds or the value of funds in exchange for an initial loading or subsequent loading of prepaid access if that person: (i) Sells prepaid access offered under a prepaid program that can be used before verification of customer identification under § 1022.210(d)(1)(iv); or (ii) Sells prepaid access (including closed loop prepaid access) to funds that exceed $10,000 to any person during any one day, and has not implemented policies and procedures reasonably adapted to prevent such a sale."
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)
Notes

Keep the agent list and a copy of the registration for five years.

Sources (5)
  • 31 CFR 1022.380(b)(3)
    "(3) Due date. The registration form for the initial registration period must be filed on or before the end of the 180-day period beginning on the day following the date the business is established. The registration form for a renewal period must be filed on or before the last day of the calendar year preceding the renewal period."
  • 31 CFR 1022.380(b)(2)
    "The initial registration period is the two-calendar-year period beginning with the calendar year in which the money services business is first required to be registered. However, the initial registration period for a money services business required to register by December 31, 2001 (see paragraph (b)(3) of this section) is the two-calendar year period beginning 2002. Each two-calendar-year period following the initial registration period is a renewal period."
  • 31 CFR 1022.380(b)(4)
    "In addition, if there is a transfer of more than 10 percent of the voting power or equity interests of a money services business (other than a money services business that must report such transfer to the Securities and Exchange Commission), the money services business must be re-registered under this section. Finally, if a money services business experiences a more than 50-per cent increase in the number of its agents during any registration period, the money services business must be re-registered under this section. The registration form must be filed not later than 180 days after such change in ownership, transfer of voting power or equity interests, or increase in agents."
  • FinCEN, MSB registration
    "filed within 180 days after the date on which the MSB is established. Registration must be renewed every two years."
  • FinCEN, BSA forms and filing requirements
    "FinCEN RMSB Form 107"
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)
Notes

The 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)
  • 31 CFR 1010.520(b)(3)(ii)
    "(ii) Report to FinCEN. If a financial institution identifies an account or transaction identified with any individual, entity, or organization named in a request from FinCEN, it shall report to FinCEN, in the manner and in the time frame specified in FinCEN's request"
  • FinCEN 314(a) fact sheet
    "Financial institutions have two weeks from the posting date of the request to respond within the secure portal with any positive matches. If the search does not uncover any matching of accounts or transactions, the financial institution is instructed not to reply to the 314(a) request."
  • FinCEN 314(a) fact sheet (search scope)
    "including accounts maintained by the named subject(s) during the preceding 12 months and transactions not linked to an account conducted within the past 6 months."
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
Notes

The 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)
  • 31 CFR 1010.230(d)
    "(d) Beneficial owner. For purposes of this section, beneficial owner means each of the following: (1) Each individual, if any, who, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, owns 25 percent or more of the equity interests of a legal entity customer;"
  • 31 CFR 1010.605(e)(1)
    "(e) Covered financial institution means: (1) For purposes of § 1010.610 and 1010.620: (i) A bank required to have an anti-money laundering compliance program under the regulations implementing 31 U.S.C. 5318(h), 12 U.S.C. 1818(s), or 12 U.S.C. 1786(q)(1); (ii) A broker or dealer in securities registered, or required to be registered, with the Securities and Exchange Commission under the Securities Exchange Act of 1934 (15 U.S.C. 78a et seq. ), except persons who register pursuant to section 15(b)(11) of the Securities Exchange Act of 1934; (iii) A futures commission merchant or an introducing broker registered, or required to be registered, with the Commodity Futures Trading Commission under the Commodity Exchange Act (7 U.S.C. 1 et seq. ), except persons who register pursuant to section 4(f)(a)(2) of the Commodity Exchange Act; and (iv) A mutual fund;"
  • FinCEN exceptive relief FIN-2026-R001
    "covered financial institutions may instead limit their identification and verification of the identities of beneficial owners under 31 C.F.R. § 1010.230(b) to the following circumstances: (1) when a legal entity customer first opens an account with a covered financial institution; (2) any time thereafter when the covered financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained about the legal entity customer; and (3) as needed based on a covered financial institution’s risk-based procedures for conducting ongoing customer due diligence."
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)
Notes

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.

Sources (3)
  • 31 CFR 1010.380(a)(1)(i)
    "(i) Any entity that becomes a reporting company on or after March 26, 2025 shall file a report within 30 calendar days of the earlier of the date on which it receives actual notice that it has been registered to do business or the date on which a secretary of state or similar office first provides public notice, such as through a publicly accessible registry, that the reporting company has been registered to do business."
  • 31 CFR 1010.380(c)(1)
    "(c) Reporting company —(1) Definition of reporting company. For purposes of this section, the term “reporting company” means: (i) [Reserved] (ii) Any entity that is: (A) A corporation, limited liability company, or other entity; (B) Formed under the law of a foreign country; and (C) Registered to do business in any State or tribal jurisdiction by the filing of a document with a secretary of state or any similar office under the law of that State or Indian tribe."
  • Final rule, 91 FR 52508
    "FinCEN is issuing this final rule to adopt as final and with certain limited changes the interim final rule issued on March 26, 2025, which narrowed beneficial ownership information (BOI) reporting requirements under FinCEN's regulations implementing the Corporate Transparency Act (CTA)."
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
Notes

A GTO lasts at most 180 days unless renewed. The MSB SAR threshold stays at $2,000.

Sources (3)
  • GTO, Covered Transaction
    "2. For purposes of this Order, a ``Covered Transaction'' means each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to the Covered Business which involves a transaction in currency, of $1,000 or more, but not more than $10,000."
  • GTO, reporting
    "5. Except as otherwise set forth in this Order, if the Covered Business is involved in a Covered Transaction, then the Covered Business shall report the Covered Transaction to FinCEN on a Currency Transaction Report within 30 days following the day on which the Covered Transaction occurred."
  • GTO, order period
    "The terms of this Order are effective beginning September 3, 2026, and [[Page 56778]] ending on March 1, 2027."
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
Notes

Exceptions include publicly traded originators and originators that are themselves financial institutions with AML program duties.

Sources (3)
  • Minnesota GTO, summary
    "FinCEN is issuing this Geographic Targeting Order, requiring banks and money transmitters located in the Counties of Hennepin and Ramsey, Minnesota to retain and report records of certain payments of $3,000 or more."
  • Minnesota GTO, timing
    "by the end of the month following the month in which the Covered Transaction took place"
  • Minnesota GTO, order period
    "The terms of this Order are effective on August 11, 2026, and end on February 6, 2027."
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.

  1. 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.
  2. 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.
  3. 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.
  4. Check the "Pending changes" column before you cite a number. Bills and proposed rules there are not law until enacted and implemented.
  5. 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.

Data: CSV · JSON. Free to reuse under CC BY 4.0 with attribution to RiskTemplates and a link to this page. Last verified October 14, 2026.

Immaterial Findings · Newsletter

The brief, in your inbox.

Enforcement of the week, a framework breakdown, and the prompts that are actually worth running. Delivered to your inbox. Free.