In January, my colleagues on the House Financial Services Committee and I began 2007 on a bipartisan note by bringing to the floor an important piece of unfinished business remaining from the 109th Congress–legislation that would relieve financial institutions from having to file Currency Transaction Reports for "seasoned customers." H.R. 323, the "Seasoned Customer Exemption Act," was swiftly approved by the House of Representatives on a voice vote and now awaits action in the Senate.
Under the federal Bank Secrecy Act financial institutions must file CTRs for cash transactions of $10,000 or greater. This filing is required even in the case of "seasoned customers": long-time bank customers that routinely deal in large volumes of cash, but whose business dealings are well enough understood to rule out the possibility of money laundering or the financing of terror.
While Suspicious Activity Reports have largely replaced CTRs as a law enforcement tool, the filing of CTRs is still required. Unfortunately, the current guidance for exempting seasoned customers from CTR filing requirements is rarely invoked because it is confusing, cumbersome, and redundant.
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