Crypto Reporting Thresholds: Why Your Exchange's Limit Isn't $10,000

Ask most people when a financial report gets filed on them and they will say $10,000. For a crypto exchange, the number that matters is much lower, and it is attached to a far more serious kind of report.

The Bullrunners video reads through the federal rules, a Government Accountability Office (GAO) report to Congress and several real cases to explain how the reporting system works. Its central warning is that the most common reaction to learning the thresholds, keeping every transaction just under them, is the one the rules are written to catch. This is general information, not legal or tax advice.

How many reports are filed for staying under the limit?

According to the GAO report cited in the video, 575,000 suspicious activity reports were filed on Americans in a single fiscal year for one reason: keeping transactions under the reporting limit. Not for fraud or laundering, but for staying under the line.

What is the $10,000 rule, and how old is it?

A bank files a currency transaction report (CTR) when someone moves more than $10,000 in cash in a day. It is automatic and says nothing about the customer’s character.

The threshold is old. The GAO wrote that the $10,000 level, set by the Treasury in 1972, has never been adjusted for inflation. The GAO’s own figures:

• Adjusted for inflation, the threshold would have been about $72,880 in 2023.
• Using an inflation-adjusted threshold would have cut the number of CTRs filed by at least 90% a year since 2014.
• From 2014 to 2023, institutions filed more than 167 million CTRs.
• Law enforcement accessed less than 3% of them.

The video’s point: a system that collects 167 million records and reads fewer than three in 100 is not targeted at anyone in particular. It collects on everyone and searches later.

What reporting thresholds apply to a crypto exchange?

Your exchange is not a bank. Under federal law it is a money services business (MSB), the same category as a check casher. FinCEN, the Treasury’s financial crimes unit, said so in its 2019 guidance on convertible virtual currency, which is why exchanges ask for your ID.

The more serious report is the suspicious activity report (SAR). A CTR is filed by a machine. A SAR is a judgment by a compliance officer that something about you looks suspicious, filed into a federal database.

Amount	What can happen	Rule cited in the video
$2,000	An MSB, including a crypto exchange, may have to file a SAR	31 CFR 1022.320
$3,000	Travel rule: your name, address, account number, the amount and date pass with the transfer	31 CFR 1010.410
$5,000	A bank may have to file a SAR	31 CFR 1020.320
Over $10,000 in cash	Automatic currency transaction report	Treasury rule from 1972

Note the direction. The lowest threshold is attached to the report that says someone suspects you. The highest is attached to the report that says nothing about you.

The MSB rule also covers transactions “conducted or attempted,” so a withdrawal you start and then cancel falls within it. FinCEN’s 2019 guidance applies the travel rule to crypto based on dollar value at the time of the transaction.

Will you find out if a SAR is filed?

No. According to the video, the regulation makes a SAR, and any information that would reveal one exists, confidential. If an exchange is subpoenaed and asked whether it filed one, it must decline and notify FinCEN. Law enforcement can receive it, but only on the condition that nobody involved is told.

The exchange must keep a copy of each SAR and its supporting documents for five years, available to FinCEN, federal, state and local law enforcement, and regulators examining the business.

In a congressional hearing shown in the video, a lawmaker noted that around 500 agencies have access to the CTR and SAR databases and asked how many individuals that means. The video says that question went unanswered.

Why is keeping transactions under the limit a mistake?

Because the rule anticipated it. Among the listed triggers for an MSB suspicious activity report, the video quotes two:

• A transaction designed, “whether through structuring or other means,” to evade reporting requirements.
• A transaction that “serves no business or apparent lawful purpose” where the MSB knows of no reasonable explanation. It does not need to be illegal, only unexplained.

Separately, 31 U.S.C. 5324 makes structuring, splitting transactions to avoid reports, a federal crime in its own right. As a lawyer in the video explains, depositing less than $10,000 is legal if you have a legitimate reason, but doing it for the purpose of avoiding the report is structuring. The money can be fully earned and taxed. The splitting is the offense.

Who has been caught by structuring rules?

The video shows two cases involving civil forfeiture, where the government takes action against the money rather than charging the person:

• Carol Hinders, who ran a restaurant in Spirit Lake, Iowa for 38 years. On May 22, 2013, IRS agents told her they had seized her business account, almost $33,000, because her frequent small cash deposits looked like structuring. Her restaurant did not take cards and she did not want cash on the premises. She was not charged with a crime.
• The Hirsch brothers of Long Island. After the government took more than $68,000, prosecutors later offered a plea deal requiring another $160,000 in fines and a guilty plea to felony structuring, which could carry up to four years in prison. They refused.

A speaker in the video describes the problem with civil forfeiture: it is easy for agencies to take money, hard for owners to get it back, and agencies can use seized funds in their own budgets.

Does this apply to crypto, or only cash?

It applies to crypto. The MSB rule covers “funds or other assets.” FinCEN’s 2019 guidance puts convertible virtual currency inside the money transmitter definition. The travel rule is measured in dollar value. And structuring is defined by intent, not by asset type.

So a holder who learns the thresholds and switches from one $9,000 withdrawal to several $1,800 withdrawals has not avoided anything. In the video’s words, he has done “the one thing the regulation names by name.”

The video draws a distinction between coins held on an exchange and coins in self-custody. On an exchange, an institution with a filing obligation sits in the middle. With keys you hold yourself, there is no institution in the middle at that layer. The video is clear this is not a way to disappear: you still owe every dollar of tax you owe.

Is Congress changing the thresholds?

Possibly. A bill called the Financial Reporting Threshold Modernization Act exists for the reasons the GAO laid out, and it has a committee report attached, meaning it has moved further than most bills. But the threshold is still $10,000 today. The video’s advice is to plan around the system that is running now, not the one that might exist later.

What to check next

1. Know which rules apply to where your crypto sits: an exchange is an MSB, not a bank.
2. Do not split transactions to stay under any threshold. That is the behavior the rules flag.
3. If you have questions about your own situation, speak to a qualified tax or legal professional.
4. Watch the Financial Reporting Threshold Modernization Act for any change to the limits.