4.26.4  Currency and Banking Retrieval System  (11-17-2006)

  1. The Currency and Banking Retrieval System (CBRS) is a system of databases operated and maintained by the Detroit Computing Center (DCC) MITS personnel. Information returns required under 26 USC, such as Form(s) 8300, and Currency Transaction Reports required under 31 USC Chapter 53, are filed at DCC, with the exception of FinCEN Form 105, Report of International Transportation of Currency and Monetary Instruments (CMIR), which is filed with Customs. DCC enters the reports, including FinCEN Form 105 received from Customs, onto various databases. All processed information is posted to the DCC mainframe and is accessible through the CBRS query system.

  2. Access to the databases is made available to government agencies engaged in criminal, tax, and other regulatory matters through a system of passwords. Access to the CBRS by outside agencies is done through the FinCEN GATEWAY system. Refer to the FinCEN web site at www.fincen.gov for additional GATEWAY information.  (11-17-2006)
CBRS User's Guide

  1. To obtain a current CBRS Users Guide, contact the MITS Help Desk at: 1-866-743-5748. If you need immediate assistance with the CBRS or have suggestions for future enhancements of the CBRS application, send an E-mail to the *MITS CBQS SUPPORT GROUP found in the IRS Outlook Directory. You may also contact DCC through their web site at http://www.dcc.irs.gov. The CBRS User Guide describes the features of CBRS and provides detailed instructions on how to use the system. An electronic version of the Users Guide is also available through the same contacts listed above.

  2. Two BSA compliance liaisons are located at DCC and are available to assist with special projects, special requests, CBRS questions and user assistance. Refer to the SB/SE BSA web site at http://sbse.web.irs.gov/FR/BSA for the DCC liaisons’ names and contact information.  (11-17-2006)
BSA Reports Found on CBRS

  1. Most of the CBRS reports have been revised and replaced with FinCEN forms. Reports and forms relating to the BSA program on CBRS include:

    • CTR, FinCEN Form 104. Form 104 replaces Form 4789, Currency Transaction Report

    • Currency Transaction Report by Casinos (CTRC), FinCEN Form 103. Form 103 replaces Form 8362, Currency Transaction Report by Casinos

    • Currency Transaction Report by Nevada Casinos (CTRC-N), FinCEN Form 103-N. Form 103-N replaces Form 8852, Currency Transaction Report by Casinos – Nevada

    • Designation of Exempt Person, FinCEN Form 110 which replaces Form TD F 90-22.53 (filed by Financial Institutions)

    • Registration of Money Services Business (MSB), FinCEN Form 107 which replaces Form TD F 90-22.55

    • Report of International Transportation of Currency and Monetary Instruments (CMIR), FinCEN Form 105. Form 105 replaces Form 4790, Report of International Transportation of Currency or Monetary Instruments

    • Report of Cash Payments Over $10,000 Received in a Trade or Business, Form 8300, a joint FinCEN and IRS form that replaces the IRS Form 8300

    • Report of Foreign Bank and Financial Accounts (FBAR), Form TD F 90-22.1

    • Suspicious Activity Report (SAR) for Depository Institutions, Form TD F 90-22.47

    • Suspicious Activity Report by Casinos and Card Clubs (SAR-C), FinCEN Form 102

    • Suspicious Activity Report by the Securities and Futures Industries (SAR-SF), FinCEN Form 101

    • Suspicious Activity Report by Money Service Businesses (SAR-MSB), Form TD F 90-22.56 (currently excludes MSB check cashers)

  2. All of the above forms are available on the FinCEN web site at www.fincen.gov and can also be obtained by calling the IRS DCC at 1-800-800-2877.  (11-17-2006)
Access and Security

  1. Revenue agents, compliance officers, and other BSA personnel are required to access the CBRS as a part of the BSA compliance examination. Every BSA case must be checked for transactions filed by the examined entity and for transactions filed on the entity. SAR filings on all entities should be reviewed for possible examination related information. Examiners may also need to retrieve information from CBRS in the course of other income tax or compliance examinations. SAR information can only be used by IRS civil examiners for BSA examinations covered under Title 31.

  2. Unique passwords are required for CBRS access.

  3. Additional profiles are required for access to the NBFI database and the Currency Underreporter Case System (CASE).

  4. For access to SAR information, call DCC at (313) 234- 2372 for CBRS user access. Management approval is required.  (11-17-2006)
User Identification and Passwords

  1. An examiner requests a CBRS user profile by submitting Form 5081through the MITS web site. The form can be found on the IRS intranet at https://ol5081.enterprise.irs.gov/. The examiner’s manager must approve this form and can also serve as the approving Functional Security Coordinator (FSC). The approved Form 5081for CBRS access is automatically submitted by the system to DCC Data Security.

  2. DCC will issue the requestor a CBRS user ID and password. After the receipt of the user ID, the user can access CBRS and will be prompted to choose a new password. It must be changed online every thirty days. For security reasons, if the user password is not timely changed, the user ID will be revoked and the user must contact the Enterprise help desk. The revocation will eventually result in the CBRS user being removed from the system and a new on-line 5081 will have to be submitted. PLEASE KEEP YOUR CBRS USER ID ACTIVE EVERY 30 DAYS to avoid an interruption in CBRS access.  (11-17-2006)
Bank Secrecy Act Coordinator Access

  1. The permanent user profile determines the degree of access to CBRS. In order to add, edit, delete, or even retrieve certain types of information from the Non-Bank Financial Institution (NBFI) database, a special profile must be requested. Each Area or BSA Territory is expected to have only two or three individuals with this type of access. These individuals usually include the BSA coordinator(s) or an individual who normally does data entry.

  2. The BSA coordinator follows the same procedure outlined for any user. However when submitting the on-line Form 5081,the CBRS user should request NBFI update and download capabilities.  (11-17-2006)
Researching CBRS

  1. Instructions on how to use the CBRS can be found in the CBRS Users Guide. Current CBRS users in your office should be contacted for assistance and system use. A new screen "SB/SE Area Code" has been added to the CBRS Main Menu selections. The current Users Guide does not provide instructions for Area Code screen use. Usage is similar to the ZIP screen. For example, on the Area Code screen, all Money Services Business registrations in an SB/SE Area can be viewed by entering the Area code number and checking RMSB.  (11-17-2006)
Examiner Uses of CBRS

  1. Compliance personnel generally use CBRS for reviewing and analyzing currency transactions. For example, in income tax examinations, CBRS can be used in an indirect method income examination. Refer to IRM 4.26.15 for general program considerations.

  2. Examiners conducting Form 8300 examinations under 26 USC 6050I may use CTRs filed on the examined entity to assist in determining when Forms 8300 should have been filed by the examined entity. For example, the examiners will review what Forms 8300 have been filed in addition to what currency transactions have been filed on the Form 8300 filing entity. A correlation may exist between currency transactions at financial institutions and Form 8300 filings.

  3. Examiners conducting Title 31 examinations use CTRs and SARs filed on the examined entity to assist in determining if the entity should be registered as a Money Service Business (MSB), and if and when BSA or Form 8300 reports should have been filed by the entity. They also use it to:

    • Determine the filing history of the examined entity and possibly other transactions conducted by the entity owner and/or employees. These can be compared to all types of Currency Transaction Reports (CTRs, CTRCs, etc.) filed on or retained by the filer to identify discrepancies and/or failures to file or other questionable Title 31 violations.

    • Query for transactions conducted by owners, managers, and employees of the financial institution or examined entity. This could detect unreported transactions of the financial institution or business that were instead reported under the individual’s name or conducted outside the normal business operations.

    • Query by the names of transactors. This query provides an additional search method when there is a retained CTR but the examiner has not been able to find a record of a filing on CBRS using filer criteria. Never assume that a name, IDN (SSN or EIN), identification type, or other data is always correct and consistently used. Entities can use multiple names (DBAs), have multiple ID numbers and multiple accounts. It is possible that the individual or business provides different identification or ID numbers or that the data was entered or transcribed incorrectly. Many BSA reports that are filed are still submitted on paper and are hand written. Be sure to query CBRS using at least one other method (name, IDN, account number, etc.). Be aware of related parties and multiple transactors and owners.

  4. Examiners may also use MSB registration information in both income tax and BSA examinations. Supporting documentation such as the MSB’s annual estimate of business volume and agent list may also be useful. While agent list requests are coordinated through FinCEN, the annual estimate of business volume is simply maintained in the MSB’s files and may be requested directly. Some of this information may be available through Internet sources and company web sites.  (11-17-2006)
Bank Secrecy Act Coordinator Uses of CBRS

  1. BSA coordinators use CBRS to identify NBFIs that should be examined. While the program encourages the use of centralized sources of inventory and entity identification, this does not preclude coordinators or examiners from using CBRS as a source or means to supplement or validate creation of BSA inventory.

    • Identification Number (IDN), address, or name (NAM) searches on CBRS may disclose cash transactions that are not consistent with the type of business listed.

    • The Occupation (OCC) database is described subsequently in this section and is designed to identify entities that have CTRs filed on them as owners as compared to Form 8300sfiled by the entity.

    • Identified financial institutions should always be included in the Title 31 database that is separately maintained by the BSA coordinator. Inventory identified for the Territory and entities not already in inventory should be added to the Title 31 database.

  2. BSA coordinators may use CBRS and the OCC database to check for businesses likely to be required to file Form 8300.

  3. Money Services Business registration forms provide detailed data, such as the number of agents, which can assist the coordinator in making risk based selections for compliance examinations.  (11-17-2006)
NBFI Database

  1. The NBFI database contained on CBRS will be periodically updated from the Title 31 database maintained by the BSA coordinators. No field employee will be required to update or delete CBRS NBFI information.

  2. The CBRS NBFI database serves only as a listing of entities that have been identified as NBFIs.  (11-17-2006)
Title 31 Database RESERVE  (11-17-2006)
Special Reports and Downloads

  1. The Detroit Computing Center (DCC) can generate special computer reports on request. A requested report may be required when the volume of transactions and information is so large that it prevents adequate analysis at a remote terminal.

  2. CBRS also has a record download feature that can provide the user with downloads of up to 5,000 records. Up to 50,000 records can be downloaded by a CBRS user with DCC permission. The download application is option 3, "QUERY DOWNLOAD" on the CBRS main menu. Downloads can be done geographically or by entity in a variety of ways (such as by name or EIN). The download information is returned to the requestor in a data file that can be uploaded into a spreadsheet. For more information, refer to the CBRS Users’ Guide section on the CBRS Download application and review the "INSTRUCTIONS FOR DOWNLOAD." The examiner may also consider requesting the assistance of a Computer Audit Specialist (CAS) to conduct the download and data file transfer.

  3. DCC also completes standardized reports designed to assist the field in identifying currency-handling entities that may be MSBs required to register and file CTRs required under Title 31 or businesses required to file Forms 8300 under Titles 26 and 31. These reports are forwarded to the BSA coordinators on a regular basis or as needed. Examples of reports available from DCC are:

    • Reports of Cash Out Entities: This report can be used to identify entities that may be cashing checks or negotiable instruments.

    • Reports of Cash In Entities: This report can be used to identify wire transfer companies, money order sellers, and entities accepting cash in the course of their trade or business that may be required to file CTRs or Form 8300.

    • Filers of Incomplete/Incorrect Form 8300: This report lists entities that have filed incomplete or incorrect Forms 8300, and the number of such forms filed by them by quarter. DCC also has a Form 8300 Penalty program that corresponds on late or incomplete Form 8300 filings and may penalize the filer for the late or incomplete filing. An examiner may also contact the DCC Form 8300 penalty section at (313) 234–1654 to inquire as to the history of a specific entity. Information about higher-volume filers with late or incomplete filings is mailed directly to the BSA coordinators to provide leads for compliance efforts and educational opportunities.

    • The Currency Underreporter Case System Report is an annual report provided to each Territory, which identifies potential underreporters indicated by analysis of the CBRS system. These are strictly Title 26 income tax case leads based on an analysis of cash activity recorded in CBRS and the filed 1040 return. CBRS also has a query section labeled "CASE" where the currency case leads can be queried.  (11-17-2006)
Securing Copies of Filed Reports

  1. In general, if specific data contained in a currency transaction document is considered essential to an examination, the examiner should print the screen for each full document. If the volume of data prohibits screen prints, the examiner should use the download feature of the CBRS to capture the data. If necessary, a request can be made to DCC via the SB/SE BSA Liaison.

  2. Photocopies of currency transaction documents should only be requested from DCC in those situations where a photocopy is required, such as when a duplicate is needed in a judicial proceeding. Only documents where the final digit of the DCN is "0" are paper filed documents. Document codes can be found on the DCN query screen of the CBRS.

  3. To obtain certified copies of filed currency transaction documents, a request containing the Document Control Number (DCN) is made in memorandum form to the BSA Compliance Department, DCC, P.O. Box 32063, Detroit, MI 48232.  (11-17-2006)
Security and Disclosure

  1. The responsibility for the security of CBRS information is placed with each person having on-line access to the CBRS data and those who have knowledge or physical custody of CBRS information, documents, or material, no matter how obtained.

  2. Examiners must not disclose CBRS information to the public. Employees with CBRS access or information must neither confirm nor deny the existence of a CBRS record to the public. SAR information is extremely sensitive data and can only be used in BSA cases.

  3. No SAR information, including the existence of a SAR, may be disclosed in the course of any BSA activity.

  4. Civil and criminal penalties may apply with respect to the unauthorized disclosure of SARs. Such disclosures undermine the very purpose for which the suspicious activity reporting system was created - the protection of our financial system through the prevention, detection, and prosecution of financial crimes and terrorist financing. The unauthorized disclosure of SARs can compromise the national security of the United States as well as threaten the safety and security of those institutions and individuals who file such reports. An unauthorized disclosure of SAR information is a very serious matter. All such unauthorized disclosures by IRS personnel will be investigated. The IRS is committed to continuing to work with FinCEN, the federal functional regulatory agencies, law enforcement, and the financial services industry to ensure that the information contained in SARs is safeguarded.

  5. Any requests for a copy of a SAR or for information relevant to the SAR will be forwarded to the BSA Policy Program Manager.

  6. For disclosure of BSA CBRS information others than SARs, refer to IRM, Disclosure of BSA Information (other than SARs) and IRM, Disclosure of BSA Information (other than SARs) Outside the IRS.

  7. Further rules relating to disclosure of financial information appear in IRM 4.26.14. BSA disclosure issues are also discussed in IRM 11.3, Disclosure of Official Information.

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