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I am trying to move a large sum of money from abroad to my bank account in the US via wire transfer and I don't want a Currency Transaction Report (CTR) being filed by my bank (if it's not necessary) as to not increase the chances of being audited.

From my understanding all banks are required to file a Currency Transaction Report (FINCEN Form 104) for “for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency of more than $10,000.”

Transaction of Currency is defined as: “The physical transfer of currency from one person to another. This does not include a transfer of funds by means of bank check, bank draft, wire transfer or other written order that does not involve the physical transfer of currency.” as per FINCEN form 104.

That being said I spoke to my bank and they told me that they automatically file the CTR for ALL transactions including international wire transfers.

My question is, if I do keep my incoming wire transfers each below $10k with the purpose of avoiding this CTR filing could I get in trouble for "structuring" or increase the chances of being "flagged" even though wire transfers aren't even considered a "Transaction of Currency" to begin with?

Thanks!

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    A wire transfer doesn't transfer currency, that is BS. Maybe the guy who you talked to didn't understand, or he doesn't what he is talking about. CTRs are for physical cash, like a briefcase with bank notes.
    – Aganju
    Apr 30, 2020 at 3:44
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    "My question is, if I do keep my incoming wire transfers each below $10k with the purpose of avoiding this CTR filing" - isn't this the definition of structuring?
    – user253751
    Sep 28, 2020 at 11:52

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Avoiding any financial reporting threshold is a crime, perhaps even imaginary ones via "conspiracy". Either way, according to the Treasury "The Internal Revenue Service Still Does Not Make Effective Use of Currency Transaction Reports"

https://www.treasury.gov/tigta/auditreports/2018reports/201830076fr.pdf

And this was before the IRS got defunded! 🎉

Honestly, even if they had auditing capacity, the IRS does not care about your +$10,000 incoming money.

Just let the arbitrarily large transaction come in, the banks have seen larger. You should have sufficient records to pass an audit. If you don't then you shouldn't be using the financial system at all because of the vast vast records regardless of what was automatically sent to the government or not.

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Transferring money through a wire transfer has no tax consequences, and does not trigger any reporting or auditing, if the money doesn't change owner (meaning it was yours before the transfer = names on sending and receiving accounts match).
If the money is not illegally earned, you have nothing to worry about.

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    You might want to clarify that you are disregarding what OP was told by the bank -- "that they automatically file the CTR for ALL transactions including international wire transfers" -- because you apparently consider it unlikely to be true. Perhaps you can suggest some way for OP to follow up and find out for sure whether the bank actually (incorrectly) does this. If it is true, then I guess you'd say the bank is incompetent, but then what should OP do about it?
    – nanoman
    Apr 30, 2020 at 6:34

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