SARs & CTRs
Two FinCEN filings: a Currency Transaction Report for cash transactions over $10,000 in one business day (aggregated), and a Suspicious Activity Report for transactions of $5,000 or more that look like laundering or have no business purpose.
The classic item hands you a scenario and asks which form, if any, fires — so train on the two triggers as a fork. If the fact pattern says “cash,” “currency,” or names a dollar figure crossing $10,000 in one business day, the answer is the CTR (FinCEN Form 112) and intent is irrelevant. If it instead describes behavior — a customer splitting deposits, refusing to give a TIN, or moving money with no apparent business purpose at the $5,000 level — the answer is the SAR (FinCEN Form 111). A near-miss trap: structuring multiple deposits at, say, $9,500 still triggers a SAR even though no single CTR threshold was hit.
Don’t confuse this with AML (the whole program these filings live inside) or CIP (identity-gathering at account opening). The favorite wrong answer is “tell the customer” or “freeze the account” — neither happens; SAR confidentiality is absolute. Memory hook: CTR = Cash + Counting dollars; SAR = Suspicion + Silence.
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