Cash over $10,000: file a CTR. Something smells wrong at $5,000 or more: escalate, file a SAR, say nothing to the customer.
- CTR: currency > $10,000, filed within 15 days.
- SAR: suspicious ≥ $5,000, within 30 days (60 if no suspect), confidential. Escalate to the AML officer; never tip off.
One report counts money, the other weighs judgment
A currency transaction report is mechanical. A firm files one for a currency transaction over $10,000 by or on behalf of one person in one business day, and the trigger is arithmetic rather than opinion. Nothing about the customer needs to be suspicious. A long-standing client with a completely lawful business who brings in $12,000 of cash generates the same report as anyone else. The firm files it within 15 days after the day of the transaction.
Keep reading: 4 more paragraphs (about 2 min)
A suspicious activity report is the opposite. It is filed where a transaction of at least $5,000 is known or suspected to involve funds from illegal activity, to be designed to evade reporting requirements, to have no business or apparent lawful purpose, or to involve the use of the firm to facilitate criminal activity. The threshold is low and the judgment is the whole point, which is why the decision does not rest with the representative alone. The firm keeps a copy of each SAR and its supporting documents for five years from the date it was filed.
The deadline runs from the day the firm detects the facts: the report is filed within 30 calendar days, extended to 60 where no suspect has been identified. Late filing is a violation in itself, which is why internal escalation has to be prompt rather than considered at leisure.
Confidentiality is the rule candidates most often break in a question. A suspicious activity report is confidential and its existence must never be disclosed to the customer or to anyone else outside the permitted channels. Warning a customer that a report has been filed, or asking them to explain themselves in a way that reveals it, is tipping off, and it is an offense separate from anything the customer may have done.
These reports go to one agency. The Financial Crimes Enforcement Network, FinCEN, is a bureau of the US Department of the Treasury. Its mission is to safeguard the financial system from illicit activity, counter money laundering and the financing of terrorism, and collect, analyze and disseminate financial intelligence. A currency transaction report for cash above $10,000, and a suspicious activity report, are filed with FinCEN under the Bank Secrecy Act rules it administers, not with FINRA, the SEC or the Office of Foreign Assets Control.
Exam terms (6)
- Currency transaction report
- Filed within 15 days for a currency transaction over $10,000 in one business day.
- Suspicious activity report
- Filed where suspicious activity of at least $5,000 is known or suspected.
- Escalation
- Referring the facts to the firm’s anti-money-laundering officer.
- Tipping off
- Telling a customer that a suspicious activity report exists; prohibited.
- Anti-money-laundering officer
- The designated person who decides whether the firm files.
- Currency
- Physical cash; the currency report is not triggered by a wire or a check.
Two reports, two triggers
| Currency transaction report | Suspicious activity report | |
|---|---|---|
| What triggers it | Currency over $10,000 in a business day | Known or suspected suspicious activity |
| Threshold | More than $10,000 | At least $5,000 |
| Form of the transaction | Physical currency only | Any form, including a wire |
| Judgment involved | None; it is arithmetic | Central; suspicion is the test |
| Deadline | Within 15 days after the transaction | Within 30 calendar days, 60 if no suspect |
| May the customer be told | Not covered by the SAR confidentiality rule | Never; disclosure is tipping off |
Try it: Decide which report each situation calls for, or neither: a customer deposits $14,000 in cash from a lawful business; a customer wires $6,000 through three accounts with no explanation and asks that nothing be recorded; a customer withdraws $11,000 by check. Then say, for the middle case, what you must not tell the customer afterwards.
Check yourself
Try a question, then read the explanation to review the rule.
Opening your study record…
Worked example
A representative notices that a customer has moved $8,000 through the account in a pattern with no apparent purpose, and asks what to do.
- Check the currency report first. Nothing here is physical cash over $10,000, so the mechanical trigger is not met and no currency transaction report arises on these facts.
- Now apply the suspicion test. The amount is at least $5,000 and the movements have no apparent business or lawful purpose, which is one of the stated grounds.
- The decision is not the representative’s to make alone. The facts go to the firm’s anti-money-laundering officer, who determines whether the firm files.
- If the firm files, the deadline is 30 calendar days from detection of the facts, extended to 60 calendar days where no suspect has been identified.
- Throughout, the customer is told nothing about the report. Asking ordinary account questions is fine; saying or implying that a report has been made is tipping off.
Same rule, new context
Opening your study record…
The closest contrast
CTR: objective, cash.
SAR: suspicion, any form.
This decides which report a scenario is testing. If the facts give you a cash amount and nothing else, the question is about the currency report; if the facts describe behavior that makes no sense, it is about suspicion, and the form of the transaction is irrelevant.
Summary
- A currency transaction report is triggered by physical currency over $10,000 in one business day and is filed within 15 days.
- A suspicious activity report is triggered by suspicion at or above $5,000, in any form of transaction.
- The suspicious activity report is filed within 30 calendar days, or 60 where no suspect is identified.
- The report is confidential; telling the customer is tipping off and is a separate offense.
Related practice
- AML pattern and escalationPractice this
Sources
- SIE Examination Content Outline (2025) · FINRA · checked 2026-10-12
- 31 CFR 1010.311 — Filing obligations for reports of transactions in currency · FinCEN · checked 2026-09-02
- 31 CFR 1023.320 — Reports by brokers or dealers of suspicious transactions · FinCEN · checked 2026-09-02
- 31 CFR 1023.320(d) — retention of SARs and supporting documentation by broker-dealers · FinCEN · checked 2026-09-04
- 31 CFR 1023.320(a)(2) — transactions a broker-dealer must report on a SAR · FinCEN · checked 2026-10-10
- About FinCEN and FinCEN mission — FinCEN.gov · FinCEN · checked 2026-09-29
- 31 CFR 1010.313 — Aggregation of multiple currency transactions · FinCEN · checked 2026-09-04
- 31 CFR 1010.306(a)(1) — Filing of reports (currency transaction report deadline) · FinCEN · checked 2026-10-09