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Department of the Treasury
Financial Crimes Enforcement Network


Issued: April 12, 2011
Subject: Preparation Guidelines for completing the March 2011 version of FinCEN Form 103, Currency Transaction Report by Casinos.

The Financial Crimes Enforcement Network ("FinCEN") is issuing this guidance to assist casinos and card clubs in correctly completing FinCEN Form 103, Currency Transaction Report by Casinos (CTR-C). On August 1, 2008, FinCEN issued a revised version of the CTR-C that became mandatory for use by all casinos and card clubs on March 1, 2009. Major differences between this version and previous versions included designation of certain fields as critical fields that require an entry, and changes to the use of special responses indicating certain required data was not available. A review of CTR-C filings identified that filers are making significant errors in several areas. First, all types of filers are failing to follow form instructions for completing critical fields. Second, electronic filers are failing to follow electronic requirement for completing dollar amount fields. Finally, FinCEN identified other less-frequent errors that are discussed below.

FinCEN strongly encourages financial institutions to sign up and utilize BSA E-filing. E-filing will eliminate most of the errors noted below because preparers must enter the required data or a special response in critical fields. An overview of the benefits of using the BSA E-Filing System can be found in the E-Filing Brochure. Information on signing up for E-filing can be found at the BSA E-Filing Home Page or by calling 1-866-346-9478 (option 1).

Critical Fields:

The current CTR-C designates certain items as critical by including an asterisk (*) in the item title. For example, item “*13 Date of birth” is critical, while item “6 Doing business as (DBA)” is not. Critical items contain information of significant value to law enforcement investigations and statistical analysis of currency transactions.

When required data is unknown in Part I Section A of the CTR-C, the special response “XX” must be used to indicate the required data is not known or does not apply. The special response "XX" demonstrates to law enforcement and analysts that the information is unknown and the casino or card club did not unintentionally omit information for the critical item. This is allowed only in Part I of the CTR-C; “XX” is not permitted in Part II and Part III critical items. 1

Furthermore, the only non-critical items on the form where “XX” is permitted as a response is “16 Customer’s Account Number.”

FinCEN’s review found that many casinos and card clubs failed to enter the special response “XX” in Part I Section A critical items when the required data was unknown or did not apply. For example, in 60 percent of CTR-Cs filed on organizations, the first name field did not contain the “XX” entry as required by form instructions. Additionally, in 38 percent of the CTR-Cs the customer Social Security Number (SSN) field failed to contain an entry. “XX” should have been entered if the information was unknown. Finally, almost 90 percent of the CTR-Cs with missing foreign customer addresses failed to contain “XX” in the state field.

The following detailed guidance explains how to correctly apply the “XX” response to those critical items in the Part I Section A when the data is unknown or does not apply.

This guidance should not be applied to other FinCEN forms unless stated explicitly in those forms' instructions or other guidance.

Electronic Filing Requirements Dollar Amount Errors

The electronic filing requirements for the CTR-C state that the item “*31 CASH IN” total or the item “*32” CASH OUT” total will be space-filled when no cash in or cash out transactions are recorded. These totals are found in the field “Enter total of CASH IN transaction(s)” at the bottom of item 31 and in the field “Enter total of CASH OUT transaction(s)” at the bottom of item 32. Approximately 26 percent of all electronically-filed CTR-Cs had zero-filled cash in total fields when there were no cash in transactions recorded. Approximately 34 percent of all electronically-filed CTR-Cs had zero-filled cash out total fields when there were no cash out transactions recorded. In both circumstances, these fields should have been space-filled The use of zero-filled cash in/cash out totals in place of a properly space-filled field may adversely affect statistics on the number of CTRs reporting cash in or cash out transactions.

There is a similar problem in the item 31 and item 32 fields for recording individual transaction dollar amounts. These are fields “a” through “h” and “z” in item 31 and “a” through “i” and “z” in item 32. Approximately 16 percent of electronically-filed CTR-Cs contained all zeros in all transaction amount fields where no dollar amount was recorded. For example, the CTR-C reports that a cash-in transaction “a Purchase(s) of casino chips…” was conducted and then reports that the transaction amount was zero. These items should be space-filled when the information is not available.

All transaction types are reported whether or not a particular type of transaction was conducted. Electronic filing requirements state that only transactions that are conducted will be reported, with the remaining transaction fields space-filled in the electronic file. The presence of transactions with zero amounts may adversely affect statistics on the numbers and types of transactions being conducted.

The electronic filing requirements for the CTR-C are available on FinCEN’s public internet site at

Other Error Issues:

Other error issues seen in CTR-C filings included:

This guidance should only be applied to the CTR-C form. Do not apply this guidance to other Bank Secrecy Act forms. Questions or comments regarding the contents of this Guidance should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.

1 In the Part II critical items there must be recorded at least one transaction greater than $10,000 or a group of transactions aggregating to more than $10,000 in either item “31 Cash in” or item “32 Cash out,” along with the associated total. Unused transaction fields will be left blank. Part II item “13 Date of transaction” must always have a date. All Part III critical items should have the required data about the casino.