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Kingsfield · Research · Banking & Financial Services

When must a bank file a currency transaction report under the Bank Secrecy Act?

Published 2026-06-23 · U.S. federal law

A financial institution must file a currency transaction report for each deposit, withdrawal, exchange, or other payment or transfer in currency of more than $10,000.

The answer

The reporting trigger

31 CFR 1010.311 requires each financial institution to file a report of each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the institution which involves a transaction in currency of more than $10,000.

The statutory hook

The regulation implements the Bank Secrecy Act's currency reporting authority. 31 U.S.C. 5313 directs the Secretary to require reports when a financial institution is involved in a transaction in currency above the prescribed amount.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft BSA/AML compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites three authorities; one of them is wrong.

AI draft excerpt — BSA/AML compliance memo
The Bank must report large cash transactions to FinCEN as part of its BSA program. Under 31 CFR 1010.311, the Bank must file a currency transaction report for each transaction in currency of more than $10,000, a duty implementing 31 U.S.C. § 5313. We advise that this cash-reporting obligation is distinct from the separate suspicious-activity reporting duty at 31 CFR 1020.320, which the Bank must not conflate with the $10,000 currency threshold.

The judge ruled on every citation as the draft used it — it accepted 31 CFR 1010.311 and 31 U.S.C. § 5313 and rejected 31 CFR 1020.320. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept31 CFR 1010.311

The draft claimed: Each financial institution must file a report of each transaction in currency of more than $10,000 (each deposit, withdrawal, exchange of currency, or other payment or transfer by, through, or to the institution).

“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. In the case of the U.S. Postal Service”

Cite found; proposition supported by the cited text.

Accept31 U.S.C. § 5313

The draft claimed: When a domestic financial institution is involved in a transaction in currency above an amount the Secretary prescribes, the institution and any participant must file a report as the Secretary prescribes.

“§ 5313 A person (except a domestic financial institution designated under subsection (b) of this section) required to file a report under this section shall file the report—”

Cite found; proposition supported by the cited text.

Reject31 CFR 1020.320

The draft claimed: Section 1020.320 sets the $10,000 currency transaction reporting threshold requiring a CTR for each cash deposit or withdrawal over that amount.

Cite found, but the cited text does not support the claim. 31 CFR 1020.320 is the suspicious activity report (SAR) rule for banks, triggered by suspicious transactions at or above $5,000, not the $10,000 currency-transaction reporting duty; the CTR requirement is at 31 CFR 1010.311. Regenerate with the correct authority.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.

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