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It is absolutely OK to tell a customer a CTR will be filed. In some cases banks have authored or purchased brochures that explain why CTRs exist. The idea is to take some of the heat off the bank, inform the customer and reassure them that they are not singled out.

CTRs must be filed whenever a customer makes a currency transaction exceeding $10,000, or for multiple transactions if the sum exceeds $10,000 in one day.

Having an IRS Currency Transaction Report on your file increases your likelihood of being audited, which is one of the reasons even people who have nothing to hide try to avoid the CTR.

Under Phase 1, transactions conducted by banks, government departments or agencies, and listed public companies and their subsidiaries are exempt from CTR reporting. Under Phase 2, transactions in currency by businesses that meet specific requirements are exempt from CTR reporting.

Note that under a separate reporting requirement, banks and other financial institutions report cash purchases of cashier's checks, treasurer's checks and/or bank checks, bank drafts, traveler's checks and money orders with a face value of more than $10,000 by filing currency transaction reports.

A CTR must be electronically filed within 15 calendar days following the day the reportable transaction occurs (31 CFR 1010.306(a)(1)). The casino must retain copies of all filed Currency Transaction Report (CTR's) for five years from the date of the report.

FinCEN regulations have consistently maintained a regulatory requirement that CTRs be filed within 15 days.