Currency Reporting in Federal Practice: Form 8300, CTRs, and SARs

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This program provides trial attorneys with a thorough grounding in the three principal currency reporting regimes that drive federal financial crime prosecutions: IRS Form 8300, Currency Transaction Reports (CTRs), and Suspicious Activity Reports (SARs). Drawing on the Bank Secrecy Act and related federal statutes, the program examines each form's legal basis, filing triggers, responsible parties, deadlines, and civil and criminal penalty exposure — equipping practitioners on both sides of the aisle to handle the full range of BSA-related matters with confidence.

Attendees will learn to identify when each reporting obligation arises, understand the critical distinctions between the three regimes, and recognize how violations are charged and prosecuted. The program addresses six key federal criminal statutes — including structuring (31 U.S.C. § 5324), money laundering (18 U.S.C. §§ 1956 and 1957), and willful BSA violations (31 U.S.C. § 5322) — and presents a robust framework of trial defenses, from the willfulness standard and the Ratzlaf doctrine to constitutional challenges and good-faith reliance on professional advice.

Four detailed hypotheticals anchor the legal analysis in real-world fact patterns, including a cash-heavy car dealership, a restaurant owner charged with structuring, a cryptocurrency exchange operator who violated the tipping-off prohibition, and an attorney who accepted a large cash retainer with potentially criminal consequences. Each scenario is examined from both the prosecution and defense perspectives.

Topics covered include: 

• Form 8300 filing obligations and the related-transactions rule
• CTR aggregation mechanics and exemptions
• SAR thresholds, red flags, and the good-faith safe harbor
• The absolute tipping-off prohibition and its discovery implications
• Structuring as a standalone offense
• Money laundering nexus and the "specified unlawful activity" element
• Willfulness as the central battleground in BSA prosecutions
• Defenses including Ratzlaf, lack of knowledge, entrapment, and constitutional challenges
• Attorney-specific obligations and the tension with privilege

Who Should Attend: Trial attorneys in federal criminal practice, white collar defense counsel, prosecutors, in-house counsel at financial institutions, and compliance professionals seeking the litigation perspective.

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