How Many $ Can Be Wired Without Generating A Ctr To The Us Government?

[Tagaa]

This post is directed to some of our more international financially astute members.

In my prepararation to leave the good old USA, I am establishing bank accounts outside of the US. I plan to move some of my liquid assets out of the country. I have read that large money wires can generate a Cash Transaction Report (CTR) that a bank is required to send to the government (unsure of which agency) for wires over a specified amount. Is there any truth to this and if so, what is the largest amount I can wire without generating said report?

Regards, Tagaa

[PeaceBlondie]

I don't know the current amount, and you need to be sure you have current info. The old trigger level was US$10,000, but after 9/11, my Chinese-American friend deposited about $8,000 cash into his credit union account, which generated a CTR under a new clause that allowed the bank to report suspicious smaller amounts.

You might also double check if the rules are any different for depositing cash funds, as opposed to withdrawing funds in cash.

[Tagaa]

Thanks for the reply Peaceblondie. I am familiar with the $10,000 limit on cash deposits(which is the current minimum to generate the CTR), but I am not refering to cash deposits or withdrawls, I am looking for information regarding international money wires. Do you have any knowledge of an amount that would generate such a report, for example wires of over $50,000, $75,000 or $100,000?

Again, many thanks, Tagaa

[jdinasia]

Thanks for the reply Peaceblondie. I am familiar with the $10,000 limit on cash deposits(which is the current minimum to generate the CTR), but I am not refering to cash deposits or withdrawls, I am looking for information regarding international money wires. Do you have any knowledge of an amount that would generate such a report, for example wires of over $50,000, $75,000 or $100,000?

Again, many thanks, Tagaa

I am realtively sure that ANY large transactions can be reported if they are thought suspicious and I believe they pulled a $Limit off that to stop people from say ... using $9999 instead of 10k

[poorfarang]

Does this apply to cash transactions outside of the usa?

Like what if a US citizen opened a Thai bank account and then had large amounts of cash deposited into this bank account from someone elses thai bank account?

[qualtrough]

Any foreign accounts over a pretty small dollar amount must be reported to the US Treasury Department. The penalties for not doing are pretty draconian, not sure how often it is enforced. I am not endorsing that, but you should check it out in case you haven't already.

[jdinasia]

Any foreign accounts over a pretty small dollar amount must be reported to the US Treasury Department. The penalties for not doing are pretty draconian, not sure how often it is enforced. I am not endorsing that, but you should check it out in case you haven't already.

I do know that those accounts are LESS than the amount required to have in an account for a retirement visa here!

[qualtrough]

Well, I googled it and here is the info from the IRS site. One thing to bear in mind is that if the total of all your accounts exceeds 10,000 ALL the acounts must be reported. <deleted> Nazis!

FS-2007-15, February 2007

With the globalization of the economy, more and more people in the U.S. have foreign financial accounts. While there are many legitimate reasons to own foreign financial accounts, there are also responsibilities that go along with owning such accounts. Foreign account owners must remember that they may have to report their accounts to the government, even if the accounts do not generate any taxable income.

Who is required to report their foreign accounts to the government, and how do they do so? The Bank Secrecy Act requires U.S. persons who own a foreign bank account, brokerage account, mutual fund, unit trust, or other financial account to file a Form TD F 90-22.1, Report of Foreign Bank and Financial Authority (FBAR), if:

1.

The person has financial interest in, signature authority, or other authority over one or more accounts in a foreign country, and

2. The aggregate value of all foreign financial accounts exceeds $10,000 at any time during the calendar year.

A U.S. person is:

*

A citizen or resident of the United States, or

*

Any domestic legal entity such as a partnership, corporation, estate or trust.

A foreign country includes all geographical areas outside the United States, the Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana Islands, and the territories and possessions of the United States (including Guam, American Samoa, and the United States Virgin Islands). An account in an institution known as a United States “military banking facility” is not considered to be an account in a foreign country.

The FBAR is not an income tax return and should not be mailed with any income tax returns. The FBAR must be mailed on or before June 30 of the following year to: U.S. Department of the Treasury, P.O. Box 32621, Detroit, MI 48232-0621.

Unlike with federal income tax returns, requests for an extension of time to file an FBAR are not granted.

A person having signature or other authority over, but no financial interest in, a foreign financial account may be excepted from filing an FBAR if they are an officer or employee of a federally-regulated bank or a federally-regulated publicly traded corporation. See the FBAR instructions for more information about this exception.

Why is it important to file the FBAR? The FBAR is required because foreign financial institutions that do not conduct business in the United States may not be subject to the same reporting requirements that domestic financial institutions are subject to (such as the requirement to file a Form 1099 to report interest paid to an account holder). Although there are legitimate purposes for having a foreign account, the FBAR is a tool to help the U.S. government identify persons who may be using foreign financial accounts to circumvent U.S. law.

Such individuals may be participating in economic crimes such as income tax evasion or embezzlement, or they may be trying to fund other illegal activity like drug trafficking or even terrorist activities.

Also, there are serious consequences for foreign account holders who choose not to honor their FBAR filing requirements. Account holders who do not comply with the FBAR reporting requirements may be subject to civil penalties, criminal penalties or both.

For an FBAR violation occurring after Oct. 22, 2004, the maximum civil penalty for a willful violation of the FBAR reporting and recordkeeping requirements is the greater of $100,000 or 50% of the balance in the account at the time of the violation. Non-willful violations can result in a penalty as high as $10,000 for each violation. Criminal violations of the FBAR rules can result in a fine and/or five years in prison.

More information on FBAR filing exceptions can be obtained on this Web site, the Money Services Businesses’ Web site at www.msb.gov and the Financial Crimes Enforcement Network’s Web site at www.fincen.gov. Help in completing Form TD F 90-22.1 is available at 1-800-800-2877, option 2. The form is available online at www.irs.gov and www.msb.gov or may be ordered by telephone at 1-800-829-3676. Questions regarding the FBAR may also be sent to [email protected].

[Carmine6]

This post is directed to some of our more international financially astute members.

In my prepararation to leave the good old USA, I am establishing bank accounts outside of the US. I plan to move some of my liquid assets out of the country. I have read that large money wires can generate a Cash Transaction Report (CTR) that a bank is required to send to the government (unsure of which agency) for wires over a specified amount. Is there any truth to this and if so, what is the largest amount I can wire without generating said report?

Regards, Tagaa

On a more practical note, why does it matter if the government is notified? Odds are you'll be moving enough money that at least some of the transfers will be reported. Unless there's some reason to worry about the government knowing (tax liens, shady associates, etc.), what's the concern?

Make the transfers, let the reports be generated, and live your life.

[IMA_FARANG]

I don't know the current amount, and you need to be sure you have current info. The old trigger level was US$10,000, but after 9/11, my Chinese-American friend deposited about $8,000 cash into his credit union account, which generated a CTR under a new clause that allowed the bank to report suspicious smaller amounts.

You might also double check if the rules are any different for depositing cash funds, as opposed to withdrawing funds in cash.

I have been told by my bank that anything over 10K dollars will generate a report. However, anything over 5K dollars is questionable, but doesn't necessarily generate a report. Having said that, I'm now trying to transfer about 31K from my staeside bank to my Thai bank for the purchase of property.

[poorfarang]

But if you are moving cash from one thai bank account into your Thai bank account would Bangkok Bank inform the US IRS that you have cash in this account?

[backflip]

" One thing to bear in mind is that if the total of all your accounts exceeds 10,000 ALL the acounts must be reported. <deleted> Nazis!"

What part of reporting financial activity do you consider to be representative of Nazism? I assume that you understand what a Nazi is.

[expatwannabe]

Lots of misinformation here.

Moving money around the U.S. or around the world doesn't create a taxable event unless it is paid to another person. If the sending and receiving accounts are all your own, there is no additional tax.

The CTR acronym refers to Cash Transaction Report - which is exactly what it means: cash. A wire is not cash; cash is limited to currency - singles, fives, tens, etc. If you deposit cash for your wire, that could generate a CTR. But the wire will not.

So if you're still worried about sending money out of the U.S. because it might be reported, then you're obviously afraid of SARs (Suspicious Activity Reports). And if you're concerned about those .. you're doing something illegal.

Edited June 22, 2007 by expatwannabe

[thohts]

All international transactions using the SWIFT/BIC system (which is most banking and equity-related transactions) are reported to US authorities. SWIFT is a cooperative in Belgium, but the database is also mirrored in the US.

Although they have access to this interbank data, it cannot be assumed that it's also reported to the IRS. However, the ability is there.

For a CTR, there is a certain algorithm that is used. Sending $9,900 of course will cause a flag. But so might two transactions of $5,000 each within a two-week period. Note that structuring transactions to avoid a CTR filing is illegal if it can be proved that it was done for no legitimate business reason.

If you send $5,000 from one bank and $5,000 from another bank in the same day you may not be subject to the reporting requirement. Check Title 31, U.S.C. § 5313 for more info.

According to Money Laundering: A Banker's Guide to Avoiding Problems:

Most vendor software systems include standard suspicious cash activity reports that

typically filter cash activity in three forms: 1) cash activity

including multiple transactions greater than $10,000; 2) cash

activity (single and multiple transactions) just below the $10,000

reporting threshold (e.g., between $8,000 - $10,000); and, 3)

cash transactions involving multiple lower-dollar transactions

(e.g., $3,000) which over a period of time (e.g., 15 days)

aggregate to a substantial sum of money. Such filtering reports,

when implemented either through the purchase of a vender

software system or through requests from the information service

provider, will enhance significantly a bank’s ability to identify

and evaluate unusual cash transactions.

Note that banks also generally keep records of purchases of cashier’s checks, money orders, and traveler’s checks in amounts over $3,000 to make sure that you're complying with the reporting requirement. Non-customer wire transactions and Pay Upon Proper Identification (PUPID) transactions are, of course, more closely scrutinized.

I think in practice, however, only transactions over about US $500,000 really raise flags. There are simply too many small-dollar transactions everyday to keep up with. (FYI, SWIFT processes about $6,000,000,000,000 -trillion- per day in transactions) Safety in numbers, I suppose.

[The above information has been provided for your reference only and is not intended to supply you with information on how to break or circumvent any laws.]

[expatwannabe]

thots

I see you visited the US Treasury website. That's fine, but you've misinterpreted the quote from the money laundering guide.

The guide you quoted says nothing about wires. It talks only about cash. And that's because that's what CTRs are about - CASH, not wires. Go ahead .. read it again.

[qualtrough]

" One thing to bear in mind is that if the total of all your accounts exceeds 10,000 ALL the acounts must be reported. <deleted> Nazis!"

What part of reporting financial activity do you consider to be representative of Nazism? I assume that you understand what a Nazi is.

Answer to Question 1:

I associate the Nazis with creeping and eventual total control of all private activities, both personal and financial, among other things. I think the increasingly onerous financial reporting and tax requirements that the US government has instituted parallel developments in Germany during the 1930s. I won't even go into the Gestapo's 1937 policy on 'enhanced interrogation', which would certainly meet with the approval of Atty. General Gonzales, although he would probably find it too mild. And don't get me started on Homeland (Heimat) Security...

Answer to Question 2:

You assumption is correct, thank you. I don't know your background, but I would be willing to wager that I know more about the NSDAP/Nazi party than you do. Offer void if you or any of your relatives were or are party members.

[thohts]

thots

I see you visited the US Treasury website. That's fine, but you've misinterpreted the quote from the money laundering guide.

The guide you quoted says nothing about wires. It talks only about cash. And that's because that's what CTRs are about - CASH, not wires. Go ahead .. read it again.

You're probably right. On the form itself at http://www.fincen.gov/forms/fin104_ctr.pdf (Part II item 30) is a box for wire transfers. But the form itself is for currency transactions. Banks probably don't use this form for wire transfers because the US authorities (thanks to SWIFT) would have it in their database.

[expatwannabe]

You're probably right.

In my previous life, I used to make sure banks reported it correctly.

Edited June 22, 2007 by expatwannabe

[chinthee]

Altert:

Everyone on this thread your IP address has been captured and transmitted to the IRS....

Just kidding, relax and have a drink, but remember that big brother has many tentacles. Dont' mess with this, report it.

[expatwannabe]

Altert:

Everyone on this thread your IP address has been captured and transmitted to the IRS....

Just kidding, relax and have a drink, but remember that big brother has many tentacles. Dont' mess with this, report it.

I'm not immune to the scrutiny. A couple years ago I sent a wire for $10,500 to my partner in Thailand. This was just about 2 years after 9/11, and the Wells Fargo clerk eyed me up and down, never smiling, while I filled out the paperwork. I felt like telling him, "look I know you have to file a suspicious activity report because this is unusual activity for me, but just do it and get that stupid look off your face!"

I held my tongue, though.

Edited June 22, 2007 by expatwannabe

[thohts]

You're probably right.

In my previous life, I used to make sure banks reported it correctly.

Maybe you could start a money-laundering consulting firm, charging just 2%. Just kidding.. but really!

[Gary A]

I don't know about what size transaction gets attention but a friend of mine was informed by his US bank that wire transfers are limited to $10,000 US dollars a day. I immediately emailed my Citibank and asked how much I could wire with a single transaction. I got the answer that I am limited to $50,000 US dollars per day. I told my friend to change banks because it appears they want to collect their $45 fee per transaction more often. The Citibank fee is a flat $30 regardless of the amount wired.

[expatwannabe]

The Citibank fee is a flat $30 regardless of the amount wired.

The amount of the wire and the amount of the fee depend on the kind of account you have.

For instance, a business account that needed to wire larger amounts regularly would no doubt be allowed.

As to the $30 wire fee, mine is less because I have a Citigold account. So everything depends.

[kdvsn]

This post is directed to some of our more international financially astute members.

In my prepararation to leave the good old USA, I am establishing bank accounts outside of the US. I plan to move some of my liquid assets out of the country. I have read that large money wires can generate a Cash Transaction Report (CTR) that a bank is required to send to the government (unsure of which agency) for wires over a specified amount. Is there any truth to this and if so, what is the largest amount I can wire without generating said report?

Regards, Tagaa

What difference does it make if a CTR report is generated?