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Bank Secrecy Act · Currency Transaction Reports · Policy v7 — annotated

§ 1Reporting obligation

The institution shall file a CTRCurrency Transaction Report — FinCEN Form 112, filed for cash transactions over the reporting threshold. for each transaction in currency of more than $10,000The CTR threshold. Aggregate multiple transactions by or on behalf of the same person on the same business day., and for multiple transactions that together exceed that amount when conducted by or on behalf of the same person during one business day.1

Aggregation is mandatory; see § 2 (Aggregation) for the method the institution applies, and § 3 (Structuring) for the related prohibition.

Argus note: Your institution's threshold matches the federal minimum. No state overlay applies in Texas.

§ 2Aggregation method

For purposes of the reporting obligation in § 1, the institution aggregates currency transactions across all branches and channels. A business dayBusiness day — the institution's posted operating day, not a calendar day; defined in the deposit account agreement. ends at the institution's cutoff time, after which transactions roll to the next reporting day.

Transactions identified after the cutoff but dated to the prior business day must be re-aggregated before filing.2 This is a common finding in examinations and warrants a documented control.

§ 3Structuring prohibition

No person shall structure, assist in structuring, or attempt to structure any transaction with one or more financial institutions for the purpose of evading the reporting requirement. A pattern of deposits just below $10,000The CTR threshold. Repeated near-threshold activity is a red flag regardless of each transaction's size. may itself be reportable as suspicious under the institution's § 4 (SAR decisioning) workflow.

§ 4SAR decisioning

Where a transaction or pattern raises suspicion, the BSA OfficerBSA Officer — the individual designated to coordinate and monitor day-to-day BSA/AML compliance. reviews it against the institution's risk profile and, if warranted, files a SARSuspicious Activity Report — FinCEN Form 111, filed within 30 days of initial detection. within the regulatory deadline. The decision — to file or not — is documented and retained for the audit trail.

  1. 1 31 CFR 1010.311. Threshold figures reflect the federal minimum in effect for the reporting period.
  2. 2 Internal control CA-BSA-014; see the institution's exam-readiness evidence binder.