Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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4/24/2006 FinCEN Posts Magnetic Media Filing Requirements for Currency Transaction Reports and Exempt Person Designations

Banks in the process of upgrading computer systems will have to make sure that they keep some old technology around for magnetic media filing of Currency Transaction Reports. FinCEN’s specifications for magnetic media filings that are sent to the IRS Detroit Computing Center (DCC) indicate that the information must be either on diskettes of the old 3.5” type with documents prepared in MS-DOS, or on computer tapes (though variations may be permitted on a case-by-case basis).  In order to file magnetically, financial institutions must satisfy acceptance testing procedures, which involve submitting a test file of between 50 and 100 documents with 95% of the test documents being error-free. Filings have to be made every two weeks on a schedule to be established with DCC.  If after submitting a magnetic filing, the institution does not receive an acknowledgment, the CTRs are not considered filed and must be resubmitted.  If an acknowledgment is sent to a filer for transactions it did not file (presumably when the acknowledgment should have been sent to another institution), the institution should notify the CTR Magnetic Media Coordinator at DCC as soon as possible.  FinCEN’s requirements for magnetic media filing of CTRs and Designations of Exempt Persons will be discussed in an upcoming issue of the Monitor.  

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