Bank Secrecy Act and Form 8300: Reporting Cash Payments Over $10,000, Identifying Prohibited Structured Transactions

An integral part of the anti-money laundering provisions of the BSA requires businesses to report the receipt of any cash payment over $10,000 arising from a single or series of transactions, on Form 8300. Even unintentional reporting failures can be costly, resulting in civil penalties per occurrence, while willful failures or attempts to evade reporting can result in criminal sanctions.

Audit and accounting advisers can play a significant role in identifying and remedying BSA disclosure failures. The statute requires businesses to report "related" receipts arising from a single or set of transactions if the aggregate cash received exceeds the $10,000 threshold. Even more critically, the anti-money laundering statute prohibits "structuring" transactions to evade BSA reporting requirements.

With the increasing presence of cash-intensive legal cannabis business and cryptocurrency transactions, BSA compliance is generating more attention from both the IRS and FinCen. BSA examinations often drag on for extended periods, and examiners can refer cases to IRS Criminal Investigation or FinCEN.

Listen as our panelist explains how to comply with BSA cash reporting requirements, handle a BSA audit and address prior noncompliance.

1. Transactions subject to reporting
2. Compliance requirements
3. Related transactions and evasion
4. The BSA audit
5. Addressing past noncompliance

The panelist will review these and other important issues:

• Identifying and reporting cash transactions subject to reporting
• Identifying related transactions subject to reporting
• Handling a BSA audit
• Addressing prior noncompliance
• Mitigating BSA penalties

Learning Objectives

After completing this course, you will be able to:

• Recognize transactions that need to be reported under BSA
• Identify related transactions that need to be reported under BSA
• Ascertain whether prior transactions should have been reported
• Determine potential remedies to past noncompliance

• Field of Study: Taxes
• Level of Knowledge: Intermediate
• Advance Preparation: None
• Teaching Method: Seminar/Lecture
• Delivery Method: Group-Internet (via computer)
• Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
• Prerequisite:

  Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).