There is no cash deposit limit on a business account, and the advice to stay under 10 thousand dollars is the part that is illegal

I gave a florist bad advice in 2019 and I have thought about it since. She had typed cash deposit limit business account into a search box, come back with 3 different answers, and asked me which one was right, because her Saturday takings were creeping past 10 thousand dollars and somebody had told her the bank reports you. I told her to break the week up and bank smaller amounts more often. I was wrong, and wrong in the direction that gets people prosecuted, because splitting deposits to stay under the line is itself the offence while the large deposit never was one.

There is no limit at all. You should read that sentence twice, because almost everybody I speak to believes the opposite, and I had believed a softer version of it myself. A business can pay in any amount of cash it likes, on any day, at any branch, and the teller has no authority to refuse it on the grounds of size alone, which is the thing I wish somebody had told the florist before she walked in with a carrier bag and started apologising to a teller who had not asked her to. What happens above a certain figure is that the bank fills in a form about it, and that figure has not moved since Richard Nixon was in office.

So I went looking for the whole rule in August, 6 years after the florist, because a reader sent me the same question in slightly different words. I read the reporting rule, the exemption rule that sits beside it, and a 110 page review of the system that the Government Accountability Office published in December 2024. I read all of it, which took most of a day and was worth the day. What follows is what the number is, who reads these reports, why your bank will probably refuse to exempt you, and how I would handle a till now.

The number is from 1972 and nobody has touched it

A bank has to file a currency transaction report on cash transactions over 10 thousand dollars in a day. The Government Accountability Office puts the age of that figure plainly: the threshold was “set in regulation by the Department of the Treasury in 1972” and “has not been adjusted for inflation”. Everything else about small business banking has moved since then. That single number has not.

The review does the arithmetic I had never bothered to do, and doing it turns a rule that looks like a deliberate policy about large sums into what it actually is, which is an old number sitting where somebody left it while the price of everything a shop buys and sells went up around it for half a century. An inflation adjusted threshold in 2023 “would have been about $72,880”. Using it “would have reduced the number of CTRs filed by at least 90 percent annually since 2014”. So roughly 9 reports in every 10 now exist because a number set during the Nixon administration was left alone, rather than because anybody decided that 10 thousand dollars is the interesting amount.

The volumes are the part I keep re-reading, and I have been back to that table 3 times. FinCEN received 20.5 million currency transaction reports in the 2024 financial year, which works out at 56,160 a day. Suspicious activity reports ran to 4.7 million. Reports of cash over 10 thousand dollars received in a trade or business, which is the Form 8300 that lands on your side of the counter rather than the bank's, came to 470,400. About 324,000 registered institutions and other filers feed the system.

Almost nobody reads them

This is where I had to stop and check I was reading the table correctly. Over the decade from 2014 to 2023, institutions filed roughly 167 million currency transaction reports. Law enforcement agencies opened about 5.4 per cent of them in the portal FinCEN runs. For the reports opened in 2023, whether through that portal or an agency's own system, the figure was under 3 per cent of the decade's filings.

The agencies are smaller than the volume suggests, which surprised me more than the totals did. The review found a median of 5 registered users per agency with portal access. I had pictured a room full of screens. What the number describes is closer to a single desk.

None of that makes the reports pointless, and I want to be careful here rather than clever, since a filing that sits unread for 6 years and then closes a fraud case has done its job better than a filing that was interesting on the day it was made. The FBI links a fifth to two fifths of its active investigations in several major programmes to these filings, depending on the programme. A report that is read once in a case that matters can justify a great deal of paperwork. What the numbers do rule out is the idea that somebody is looking at your florist takings.

What the paperwork costs the bank

FinCEN told the paperwork regulator in 2020 that a report takes about 8 minutes to complete, with a total annual cost burden of 54.7 million dollars, which the auditors worked out at roughly 3.40 dollars a report. Banks dispute that estimate flatly. One bank representative said the branch manager review alone “can take about 45 minutes”.

I find that gap more interesting than either number. It explains the behaviour you meet at the counter. Tellers are not suspicious of you. They are 8 minutes behind, or 45, and the form asks for identification details they have to key in correctly on a day when the queue is long.

The exemption almost nobody gets

Here is the part of the rules that surprised me, and it is the part worth acting on. There is a standing mechanism to take a cash heavy business out of the reporting entirely. A bank may designate a customer as an exempt person, and once it has, the reports stop for that account.

The second tier covers ordinary companies. The rule describes it as “any other commercial enterprise” that maintains a transaction account at the bank for at least 2 months and “frequently engages in transactions in currency with the bank in excess of $10,000”. A sole proprietorship counts as one. So does a firm that regularly takes out more than 10 thousand dollars in cash to pay staff, which the rules treat as a payroll customer, defined in practice as 5 or more such withdrawals in a year.

The bank files one designation form, FinCEN Form 110, and reviews the customer once a year. The two month wait can be waived if the bank documents a risk assessment and “forms a reasonable belief that the customer has a legitimate business purpose for conducting frequent transactions in currency”. That is the whole mechanism. It has existed for decades.

Some trades are shut out by name. The ineligible list runs to motor vehicle, vessel, aircraft, farm equipment and mobile home sales, the practice of law, accountancy or medicine, auctioning, chartering ships, buses or aircraft, gaming other than licensed parimutuel betting, investment advice and investment banking, real estate brokerage, pawn brokerage, title insurance and real estate closing, and trade union activity. A mixed business is still eligible if no more than half its gross revenue comes from those activities.

Handling a till that goes over the line

Bank the whole amount, every single time. If your Saturday is 14 thousand dollars, pay in 14 thousand dollars on Monday, and never divide it into 2 trips, 2 branches or 2 days. Splitting cash to keep each deposit under the line is a separate federal offence under the structuring statute, and the fact that the underlying money is clean is not a defence to it. This is the correction to the advice I gave in 2019 and I would like it read more than anything else here.

Expect to be asked for identification and for the source of the cash, and treat the questions as the form rather than as an accusation. Your bookkeeper should note the date, the amount and the deposit reference, so that if anybody asks in 2 years there is a line to point at.

Ask about a Phase II exemption if you are consistently over the line. Ask the relationship manager rather than the branch counter, use the words exempt person and Form 110, and expect no. A no costs you one conversation. A yes ends the paperwork for the account.

Watch your own reporting duty separately. If a customer pays your business more than 10 thousand dollars in cash, in one go or in related payments, the Form 8300 obligation is yours and not the bank's. That is a different form with its own deadline, and 470,400 of them were filed in the last financial year, so plenty of ordinary businesses are meeting it.

We are describing rules rather than giving advice, and a bank compliance officer or your accountant is the person to ask before you change anything about how a real business handles cash. It is not a subject where a reader should act on a newspaper, and if the answer you get from your own bank contradicts anything above, the bank is the one holding the examination risk and the one whose answer decides what happens to your account on Monday morning.

Why your bank will probably say no anyway

I had assumed the exemption was underused because customers had never heard of it. That is not what the review found. Representatives of large and regional banks said their institutions use minimal exemptions because exemptions “are more time-consuming, costlier, and pose greater compliance risk than filing CTRs”. Smaller institutions gave a similar answer.

Read it from the bank's side and the behaviour is rational. Filing is routine, cheap per event and safe. Nobody has ever been sanctioned for filing one too many, whereas an exemption granted to the wrong customer is exactly the kind of decision that gets read back to a compliance officer in a room where the outcome is already known and the only question left is who signed it. Exempting a customer is a judgement. A judgement has to be defended to an examiner if the customer later turns out badly. So the system files 20.5 million reports a year partly because filing is the option nobody gets criticised for.

My guess is that a small community bank is likelier to say yes than a large one, since the relationship is closer and the officer already knows the business. I have not found published figures either way. It is a guess, and I am not going to pretend it is more than one.

A short digression about the word suspicious

Two different reports get confused constantly, including by me until this month. A currency transaction report is automatic and says nothing about you. A suspicious activity report is a judgement and says a great deal, and the bank is not allowed to tell you it filed one. The first kind ran to 20.5 million last year. The second kind ran to 4.7 million, which is still an enormous number, and the difference between them is the entire emotional content of this subject. The confusion costs people sleep, and it costs them the wrong decision at the counter, because somebody who believes the first form is an accusation will start doing the one thing that turns a clean week of takings into a criminal matter. Anyway, back to the counter.

What I could not establish

How many businesses hold an exemption today. FinCEN publishes filing counts by form type, and I have not found any published count of active designations of exempt person. Without it I cannot tell you whether the mechanism is dying or merely narrow, and the difference matters to every shop owner who is about to have this conversation with a relationship manager who has also never processed one. I asked 2 people who work in bank compliance and both said they had never processed one, which is 2 people and proves nothing.

Whether the threshold will move. The auditors recommended that FinCEN cut the number of unused reports, including by raising the threshold, and FinCEN agreed with all 4 recommendations in a letter in June 2025. Agreement is not a rule change. I do not know of any proposed figure, and I would not plan a business around one arriving, because a number that survived 54 years of inflation untouched has already shown what it does when left alone.

The detail I still cannot get past is the 60 per cent. Roughly 3 filings in every 5 over the past decade had a business somewhere on them, which means this system is mostly a record of ordinary shops banking their week. Nobody I asked would say what proportion of those reports has ever been opened by a human being, and I suspect the honest answer is that the question is not tracked at all.