# FinCEN Ruling FIN-1988-R005: (Formerly known as 88-5) Does a financial institution havea duty to file a CTR on currency transactions where the financial institution never physically receives the cash because it uses an armored car service to collect, transport and process > Federal · Rulings · In force URL: https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1988R005 ## Section - **Citation:** FinCEN Ruling FIN-1988-R005 - **Heading:** (Formerly known as 88-5) Does a financial institution havea duty to file a CTR on currency transactions where the financial institution never physically receives the cash because it uses an armored car service to collect, transport and process - **Jurisdiction:** Federal - **Kind:** Rulings - **Status:** In force - **Text as of:** August 14, 2026 - **Source:** Compiled text - **Location:** FinCEN Administrative Rulings / (Formerly known as 88-5) Does a financial institution havea duty to file a CTR on currency transactions where the financial institution never physically receives the cash because it uses an armored car service to collect, transport and process ## Text Facts X State Bank (the "Bank") and Acme Armored Car Service ("Acme") have entered into a contract which provides for Acme to collect, transport and process revenues received from Bank customers: Each day, Acme picks up cash, checks, and deposit tickets from Little Z, a non-exempt customer of the Bank. Recently, receipts of cash from Little Z have exceeded $ 10,000. Acme delivers the checks and deposit tickets to the Bank where they are processed and Little Z’s account is credited. All cash collected, however, is taken by Acme to its central office where it is counted and processed. The cash is then delivered by Acme to the Federal Reserve Bank for deposit into the Bank’s account. Must the Bank file a CTR to report a receipt of cash in excess of $ 10,000 by Acme from Little Z? Law and Analysis Yes. Since Acme is receiving cash in excess of $ 10,000 on behalf of the Bank, the Bank must file a CTR in order to report these transactions. Under the facts presented, Acme is acting as an agent of the Bank. This is because Acme and the Bank have a contractual relationship whereby the Bank has authorized Acme to pick up, transport and process Little Z’s receipts on behalf of the Bank. The Federal Reserve Bank’s acceptance of deposits from Acme into the Bank’s account at the Fed, is additional evidence of the agency relationship between the Bank and Acme. Therefore, when Acme receives currency in excess of $ 10,000 from Little Z, the Bank must report that transaction on Form 4789. Likewise, if Acme receives currency from Little Z in multiple transactions, § 103.22(a)(1) requires the Bank to aggregate these transactions and file a single CTR for the total amount of currency received by Acme, if the Bank has knowledge of these multiple transactions. Knowledge by the Bank’s agent, i.e., Acme, that the currency was received in multiple transactions, is attributable to the Bank. The Bank must assure that Acme, as its agent, obtains all the information and identification necessary to complete the CTR. Holding actions and file a single CTR for the total amount of currency received by Acme, if the Bank has knowledge of these multiple transactions. Knowledge by the Bank’s agent, i.e., Acme, that the currency was received in multiple transactions, is attributable to the Bank. The Bank must assure that Acme, as its agent, obtains all the information and identification necessary to complete the CTR. Holding Financial institutions must file a CTR for the currency received by an armored car service from the financial institution’s customer when the armored car service physically receives the cash from the customer, transports it and processes the receipts, even though the currency may never physically be received by the financial institution. This is because the armored car service is acting as an agent of the financial institution. ## Nearby sections - [FinCEN Ruling FIN-1988-R005 (Formerly known as 88-5) Does a financial institution havea duty to file a CTR on currency transactions where the financial institution never physically receives the cash because it uses an armored car service to collect, transport and process](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1988R005.md) - [FinCEN Ruling FIN-1989-R002 (Formerly known as 89-2) When a customer has established bank accounts for each of several establishments that it owns, and the bank has exempted one or more of those accounts, how does the bank aggregate the customer`s currency transactions?](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1989R002.md) - [FinCEN Ruling FIN-1989-R005 (Formerly known as 89-5) How does a financial institution fulfill the requirement that it furnish information about the person on whose behalf a reportable currency transaction is being conducted?](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1989R005.md) - [FinCEN Ruling FIN-1992-R001 (Formerly known as 92-1) How does a financial institution fulfill the requirement to verify and record the name and address of an elderly or disabled individual who conducts a currency transaction in excess of $ 10,000](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1992R001.md) - [FinCEN Ruling FIN-1992-R002 How should a financial institution complete a CTR when multiple transactions are aggregated and reported on a single form and all or part of the information called for in the form may not be known?](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1992R002.md) - [FinCEN Ruling FIN-2000-R001 Currency Transaction Reporting: Guidance on Completing CTR Section A "Person(s) on Whose Behalf Transaction(s) is Conducted](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2000R001.md) - [FinCEN Ruling FIN-2001-R001 Currency Transaction Reporting: Completing a CTR and Aggregation](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2001R001.md) - [FinCEN Ruling FIN-2001-R002 Currency Transaction Reporting: Aggregation](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2001R002.md) - [FinCEN Ruling FIN-2002-R001 Whether a Business that Cashes Checks Payable to Customers to Apply Proceeds to the Repayment of Customers’ Obligations is a Money Services Business](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2002R001.md) - [FinCEN Ruling FIN-2002-R002 Definition of Check Casher (Payday Lenders)](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2002R002.md) - [FinCEN Ruling FIN-2003-R001 Currency Transaction Reporting: Aggregation](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2003R001.md) - [FinCEN Ruling FIN-2003-R002 Definition of "Foreign Shell Bank" and "Foreign Bank](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2003R002.md) - [FinCEN Ruling FIN-2003-R003 Currency Transaction Reporting: Transactions between Money Transmitters and their Agents](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2003R003.md) - [FinCEN Ruling FIN-2003-R004 Definition of Money Transmitter/Stored Value (Gift Certificates/Gift Cards)](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2003R004.md) --- Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FINCEN_FIN1988R005. Check the current official text before relying on it. Not legal advice.