FIN-2023-Alert005: Prevalent virtual currency investment scam known as 'pig butchering'

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Fincen

2023-09-08

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

FIN-2023-Alert005                                                            September 8, 2023

 FinCEN Alert on Prevalent Virtual Currency Investment Scam
           Commonly Known as “Pig Butchering”
                                        The U.S. Department of the Treasury’s Financial Crimes
     Suspicious Activity Report (SAR)
                                        Enforcement Network (FinCEN) is issuing this alert to
     Filing Request:
                                        U.S. financial institutions1 and the broader public to bring
  FinCEN requests that financial
                                        attention to a prominent virtual currency investment scam
  institutions reference this alert in
                                        called “pig butchering.”2 These scams are referred to as “pig
  SAR field 2 (Filing Institution Note
                                        butchering” as they resemble the practice of fattening a hog
  to FinCEN) and the narrative by
                                        before slaughter. The victims in this situation are referred to
  including the key term “FIN-2023-
  PIGBUTCHERING” and selecting          as “pigs” by the scammers who leverage fictitious identities,
  “Fraud-Other” under SAR field         the guise of potential relationships, and elaborate storylines
  34(z) with the description “Pig       to “fatten up” the victim into believing they are in trusted
  Butchering.”                          partnerships. The scammers then refer to “butchering”
                                        or “slaughtering” the victim after victim assets are stolen,
causing the victims financial and emotional harm. In many cases, the “butchering” phase involves
convincing victims to invest in virtual currency,3 or in some cases, over-the-counter foreign
exchange schemes4—all with the intent of defrauding them of their investment.5 Pig butchering
scams are largely perpetrated by criminal organizations based in Southeast Asia who use victims

1.    See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t).
2.    United States Secret Service (USSS), “Cryptocurrency Investment Scams” (USSS Alert). These scams are also called
      “Sha Zhu Pan,” a Chinese term that loosely translates to pig butchering. These scams may also be referred to, or
      begin as, “confidence scams” (or in certain cases “romance scams”) because fraudsters gain the confidence of their
      victims before eventually enticing them to make investments in fraudulent virtual currency trading platforms. See
      U.S. Department of Justice (DOJ), U.S. Attorney’s Office, Central District of California Press Release, “Justice Dept.
      Seizes Over $112M in Funds Linked to Cryptocurrency Investment Schemes, With Over Half Seized in Los Angeles
      Case” (Apr. 3, 2023).
3.    Various types of virtual currency are known to be used in these scams, including prevalent cryptocurrencies and
      stablecoins, such as bitcoin, ether, U.S. dollar tether, and TRX, among others. FinCEN’s definitions and consolidat-
      ed guidance concerning virtual currency may be found at FinCEN, “Application of FinCEN’s Regulations to Certain
      Business Models Involving Convertible Virtual Currencies” (May 9, 2019).
4.    While the majority of instances of this scam are perpetrated using virtual currency, scammers have increased their reli-
      ance on other ways to steal money, including electronic funds transfers, wire transfers, and foreign currency and dol-
      lar-gold contracts (Forex). See Commodity Futures Trading Commission (CFTC) Advisory, “Customer Advisory: Avoid
      Forex, Precious Metals, and Digital Asset Romance Scams” (Feb. 7, 2022), and CFTC Press Release, “CFTC Charges Cal-
      ifornia Resident and His Corporation with Fraud and Misappropriation in a Popular Romance Scam Involving Digital
      Asset Commodities and Forex” (Jun. 22, 2023). This alert focuses on the virtual currency instances of this scam.
5.    See New Jersey Attorney General, Press Release, “Bureau of Securities Orders Three Website Operators to Stop
      Offering Fraudulent Cryptocurrency Investment Opportunities, Urges NJ Residents to Beware of “Pig Butchering”
      Scams” (Feb. 3, 2023) (NJ AG Press Release). See also DOJ, “Eleven Defendants Arrested for Investment Fraud, Money
      Laundering and Unlicensed Money Transmitting Business Schemes” (Oct. 13, 2022), and DOJ, U.S. Attorney’s Office,
      District of New Jersey Press Release, “Middlesex County Man Charged with Laundering $2.1 Million Obtained from
      Internet-Related Frauds” (Oct. 11, 2022).
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of labor trafficking to conduct outreach to millions of unsuspecting individuals around the world.6
Multiple U.S. law enforcement sources estimate victims in the United States have lost billions of
dollars to these scams and other virtual currency investment frauds.7

This alert explains the pig butchering scam methodology, provides red flag indicators to assist
with identifying and reporting related suspicious activity, and reminds financial institutions of
their reporting requirements under the Bank Secrecy Act (BSA). Pig butchering scams are linked
to fraud and certain types of cybercrime, which are two of FinCEN’s Anti-Money Laundering and
Countering the Financing of Terrorism (AML/CFT) National Priorities.8

The information contained in this alert is derived from FinCEN’s analysis of BSA data, open-
source reporting, and information from law enforcement partners.

                          Methodology of a Pig Butchering Scam
Initial Contact with Victim

A scammer9 typically makes initial contact with                      Scammers may communicate with
a potential victim through text messages, direct                     victims using:
messages on social media, or other communication
                                                                     • Instant messaging services and text
tools and platforms, usually under the guise of
                                                                       messages
accidentally reaching a wrong number or trying
                                                                     • Professional networking sites
to re-establish a connection with an old friend.10
                                                                     • Social media
The scammer, who may claim to be an investor or
                                                                     • Dating sites
money manager, may also create a social media

6.   Michigan Department of Attorney General, Consumer Protection Division, “Cryptocurrency Scam – Pig Butchering”
     (Michigan AG Alert), and Federal Bureau of Investigation (FBI) Internet Crime Complaint Center (IC3) Public Service
     Announcement (PSA), “The FBI Warns of False Job Advertisements Linked to Labor Trafficking at Scam Compounds”
     (May 2023 FBI PSA) (May 22, 2023).
7.   FBI PSA, “The FBI Warns of a Spike in Cryptocurrency Investment Schemes,” (March 2023 FBI PSA) (Mar. 14, 2023).
     In 2022, investment fraud, as a general category, caused the highest losses of any scam reported by the public to the
     FBI IC3, totaling $3.31 billion. Fraud involving cryptocurrency, including pig butchering, represented the majority of
     these scams, and increased 183% from 2021 to a total of $2.57 billion in reported losses in 2022. FBI IC3, “2022 Internet
     Crime Report” (Mar. 9, 2023), at p. 12.
8.   FinCEN, “Anti-Money Laundering and Countering the Financing of Terrorism National Priorities” (Jun. 30, 2021).
     FinCEN periodically releases alerts and advisories on the use and abuse of virtual currencies. See FinCEN, “Advisory
     on Illicit Activity Involving Convertible Virtual Currency” (May 9, 2019). See also FinCEN, “Advisory on Ransomware
     and the Use of the Financial System to Facilitate Ransom Payments” (Nov. 8, 2021); and FinCEN, “Advisory on Cy-
     bercrime and Cyber-Enabled Crime Exploiting the Coronavirus Disease 2019 (COVID-19) Pandemic” (Jul. 30, 2020);
     FinCEN, “Ransomware Trends in Bank Secrecy Act Data between January 2021 and June 2021” (Oct. 15, 2021); and
     FinCEN, “Ransomware Trends in Bank Secrecy Act Data between July 2021 and December 2021” (Nov. 1, 2022).
9.   According to media reports and law enforcement sources, a significant number of scammers who contact victims are
     likely victims themselves of human and labor trafficking rings operated by criminal organizations and are perpetrat-
     ing such activity against their will. See May 2023 FBI PSA, supra note 6.
10. FBI PSA, “Cryptocurrency Investment Schemes” (October 2022 FBI PSA) (Oct. 3, 2022).

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profile which showcases wealth and an enviable lifestyle.11 Once the scammer elicits a response
from a victim, the scammer will communicate with them over time to establish trust and build a
relationship.12

The “Investment” Sales Pitch

Once trust or a relationship has been established, the scammer will introduce the victim to a
supposedly lucrative investment opportunity in virtual currency and direct them to use virtual
currency investment websites or applications designed to appear legitimate, but which are
fraudulent and ultimately controlled or manipulated by the scammer.13 This includes the use of
legitimate applications with third-party plugins that allow the scammer to manipulate or falsify
information presented to the victim. A scammer may also request remote access to the victim’s
devices to register accounts with virtual currency service providers (i.e., virtual asset service
providers, or VASPs) on the victim’s behalf, or instruct their victims to take screenshots of their
device so that the scammers can walk them through the process of purchasing virtual currency.
According to the FBI, many victims also report being directed to make wire transfers to overseas
accounts or purchase large amounts of prepaid cards to purchase virtual currency. The use of
virtual currency and virtual currency kiosks is also an emerging method of payment.14 Once a
victim acquires virtual currency, the scammer directs them to “invest” the funds through the
investment websites or applications, although the funds are funneled to virtual currency addresses
and accounts controlled by scammers and their co-conspirators.

Occasionally, a scammer will leverage high-pressure sales tactics such as telling their victim that
they will lose out on the opportunity if they do not invest by a certain deadline.15 A scammer may
also encourage the victim to bring their friends and family to invest into the scheme. In more
recent iterations, the scammer will invite the victim to join online or mobile games, advertised as
“play-to-earn” games offering financial incentives to players, but which in reality are fake gaming
applications created by the scammer to steal virtual currency from players.16

The Promise of Greater Returns

Once the victim invests with the scammer, the scammer will show the victim extraordinary
returns on the investment that have been fabricated.17 The scammer may even allow the victim to
withdraw a small amount of that investment to further build the victim’s confidence before urging

11. See Michigan AG Alert, supra note 6.
12. USSS Alert, supra note 2, and October 2022 FBI PSA, supra note 10.
13. October 2022 FBI PSA, supra note 10, and March 2023 FBI PSA, supra note 7.
14. October 2022 FBI PSA, supra note 10.
15. FBI PSA, “Scammers Defraud Victims of Millions of Dollars in New Trend in Romance Scams” (September 2021 FBI
    PSA) (Sept. 16, 2021).
16. FBI PSA, “Criminals Steal Cryptocurrency through Play-to-Earn Games” (Mar. 9, 2023).
17. October 2022 FBI PSA, supra note 10.

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the victim to invest more.18 Victims have been known to liquidate holdings in tax-advantaged
accounts or take out home equity lines of credit (HELOC) and second mortgages on their homes in
order to increase their investments.

The Point of No Return

When a victim’s pace of investment slows or stops, the scammer will use even more aggressive
tactics to extract any final payments. The scammer may present the victim with supposed losses
on the investment and encourage them to make up the difference through additional deposits. If
the victim attempts to withdraw their investment, the scammer may demand that the victim pay
purported taxes or early withdrawal fees.19 Once the victim is unable or unwilling to pay more
into the scam, the scammer will abruptly cease communication with the victim, taking the victim’s
entire investment with them.

        Case Study: Court Authorizes the Seizure of Domains Used in Furtherance of a
                          Cryptocurrency Pig Butchering Scheme

  In November 2022, the U.S. Attorney’s Office for the Eastern District of Virginia announced
  the seizure of seven domain names used in a pig butchering scam. According to court records,
  from at least May through August 2022, scammers induced five victims in the United States by
  using the seven seized domains, which were all spoofed domains of the Singapore International
  Monetary Exchange. The term “spoofed” refers to domain spoofing and involves a cyberattack
  in which fraudsters or hackers seek to persuade individuals that a web address or email belongs
  to a legitimate and generally trusted company, when in fact it links the user to a false site
  controlled by a cybercriminal. The scammers convinced the victims that they were investing
  in a legitimate cryptocurrency opportunity. After the victims transferred investments into the
  deposit addresses that the scammers provided through the seven seized domain names, the
  victims’ funds were immediately transferred through numerous private wallets and swapping
  services in an effort to conceal the source of the funds. In total, the victims lost over $10 million.20

18. September 2021 FBI PSA, supra note 15.
19. September 2021 FBI PSA, supra note 15.
20. DOJ, U.S. Attorney’s Office, Eastern District of Virginia Press Release, “Court Authorizes the Seizure of Domains Used
    in Furtherance of a Cryptocurrency ‘Pig Butchering’ Scheme” (Nov. 21, 2022).

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                                           Red Flag Indicators
FinCEN, in consultation with law enforcement, has identified the following indicators to help
detect, prevent, and report potential suspicious activity related to pig butchering. As no single red
flag is determinative of illicit or other suspicious activity, financial institutions should consider the
surrounding facts and circumstances, such as a customer’s historical financial activity, whether
the transactions are in line with prevailing business practices, and whether the customer exhibits
multiple red flags, before determining if a behavior or transaction is suspicious or otherwise
indicative of pig butchering. In line with their risk-based approach to compliance with the BSA,
financial institutions are also encouraged to perform additional due diligence where appropriate.

Behavioral Red Flags

      A customer with no history or background of using, exchanging, or otherwise interacting
      with virtual currency attempts to exchange a high amount of fiat currency from an existing or
      newly opened bank account for virtual currency or attempts to initiate high-value transfers to
      VASPs.

      A customer mentions or expresses interest in an investment opportunity leveraging virtual
      currency with significant returns that they were told about from a new contact who reached
      out to them unsolicited online or through text message.21

      A customer mentions that they were instructed by an individual who recently contacted them
      to exchange fiat currency for virtual currency at a virtual currency kiosk and deposit the
      virtual currency at an address supplied by the individual.22

      A customer appears distressed or anxious to access funds to meet demands or the timeline of
      a virtual currency investment opportunity.

Financial Red Flags

      A customer uncharacteristically liquidates savings accounts prior to maturation, such as a
      certificate of deposit, and then subsequently attempts to wire the liquidated fiat currency to a
      VASP or to exchange them for virtual currency.

      A customer takes out a HELOC, home equity loan, or second mortgage and uses the proceeds
      to purchase virtual currency or wires the proceeds to a VASP for the purchase of virtual
      currency.

      A customer receives what appears to be a deposit of virtual currency from a virtual currency
      address at or slightly above the amount that the customer previously transferred out of
      their virtual currency account. This deposit is then followed by outgoing transfers from the
      customer in substantially larger amounts.
21. October 2022 FBI PSA, supra note 10, and USSS Alert, supra note 2.
22. October 2022 FBI PSA, supra note 10.

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      Accounts with large balances that are inactive or have limited activity begin to show constant,
      uncharacteristic, sudden, abnormally frequent, or significant withdrawals of large amounts of
      money being transferred to a VASP or being exchanged for virtual currency.

      A customer sends multiple electronic funds transfers (EFTs) or wire transfers to a VASP or
      sends part of their available balance from an account or wallet they maintain with a VASP and
      notes that the transaction is for “taxes,” “fees,” or “penalties.”23

      A customer with a short history of conducting several small-value EFTs to a VASP abruptly
      stops sending EFTs and begins sending multiple high-value wire transfers to accounts of
      holding companies, limited liability corporations, and individuals with which the customer
      has no prior transaction history. This is indicative of a victim sending trial transactions to a
      scammer before committing to and sending larger amounts.

Technical Red Flags

      System monitoring and logs show that a customer’s account is accessed repeatedly by unique
      IP addresses, device IDs, or geographies inconsistent with prior access patterns. Additionally,
      logins to a customer’s online account at a VASP come from a variety of different device IDs
      and names inconsistent with the customer’s typical logins.

      A customer mentions that they are transacting to invest in virtual currency using a service that
      has a website or application with poor spelling or grammatical structure, dubious customer
      testimonials, or a generally amateurish site design.24

      A customer mentions visiting a website or application that is purported to be associated
      with a legitimate VASP or business involved in investing in virtual currency. The website or
      application shows warning signs such as a web address or domain name that is misspelled
      in such a manner as to resemble that of another business, a recently registered web address
      or domain name, no physical street address, international contact information, or contact
      methods that include only chat or email.25

      A customer mentions that they downloaded an application on their phone directly from
      a third-party website, rather than from a well-known third-party application store or an
      application store installed by the manufacturer of the device.

      A customer receives a large amount of virtual currency such as ether at an exchange,
      subsequently converts the amount to a virtual currency with lower transaction fees such as
      TRX, and then abruptly sends it out of the exchange.

23. See NJ AG Press Release, supra note 5.
24. USSS Alert, supra note 2.
25. October 2022 FBI PSA, supra note 10. Another indicator is that the supposedly legitimate business is not registered
    with FinCEN as a money services business (MSB). MSB registrations may be searched online at: https://www.fincen.
    gov/msb-registrant-search.

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                                         Pig Butchering Fraud Reporting

  In addition to filing a SAR, financial institutions are encouraged to refer their customers who
  may be victims of pig butchering to the FBI’s IC3: https://www.ic3.gov/, and may also refer their
  customers to the Securities and Exchange Commission’s tips, complaints, and referrals (TCR)
  system to report investment fraud: https://www.sec.gov/tcr.

  In the case of elder victims of pig butchering, financial institutions may also refer their
  customers to DOJ’s National Elder Fraud Hotline at 833-FRAUD-11 or 833-372-8311.

          Reminder of Relevant BSA Obligations and Tools
                   for U.S. Financial Institutions
                  Suspicious Activity Reporting
                  Other Relevant BSA Reporting
    USA PATRIOT ACT Section 314(b) Information Sharing Authority

                                        Suspicious Activity Reporting
  A financial institution is required to file a SAR if it knows, suspects, or has reason to suspect a
  transaction conducted or attempted by, at, or through the financial institution involves funds
  derived from illegal activity; is intended or conducted to disguise funds derived from illegal
  activity; is designed to evade regulations promulgated under the BSA; lacks a business or
  apparent lawful purpose; or involves the use of the financial institution to facilitate criminal
  activity, including pig butchering.26 All statutorily defined financial institutions may voluntarily
  report suspicious transactions under the existing suspicious activity reporting safe harbor.27

  When a financial institution files a SAR, it is required to maintain a copy of the SAR and the
  original or business record equivalent of any supporting documentation for a period of five
  years from the date of filing the SAR.28 Financial institutions must provide any requested
  documentation supporting the filing of a SAR upon request by FinCEN or an appropriate law
  enforcement or supervisory agency.29 When requested to provide supporting documentation,
  financial institutions should take special care to verify that a requestor of information is, in
  fact, a representative of FinCEN or an appropriate law enforcement or supervisory agency. A

26. See 31 CFR §§ 1020.320, 1021.320, 1022.320, 1023.320, 1024.320, 1025.320, 1026.320, 1029.320, and 1030.320.
27. See 31 U.S.C. § 5318(g)(3). Financial institutions may report suspicious transactions regardless of amount involved
    and still take advantage of the safe harbor.
28. See 31 CFR §§ 1020.320(d), 1021.320(d), 1022.320(c), 1023.320(d), 1024.320(c), 1025.320(d), 1026.320(d), 1029.320(d),
    1030.320(d).
29. Id.; see also FinCEN, “Suspicious Activity Report Supporting Documentation” (Jun. 13, 2007).

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  financial institution should incorporate procedures for such verification into its BSA compliance
  or AML program. These procedures may include, for example, independent employment
  verification with the requestor’s field office or face-to-face review of the requestor’s credentials.

                                                 SAR Filing Instructions
  When filing a SAR in connection with this alert, FinCEN requests that financial institutions
  include the key term “FIN-2023-PIGBUTCHERING” in SAR field 2 (Filing Institution Note
  to FinCEN) and the narrative to indicate a connection between the suspicious activity being
  reported and the activities highlighted in this alert. Financial Institutions should also select
  “Fraud-Other” under SAR field 34(z) with the description “Pig Butchering.”

  Financial institutions should include any and all available information relating to the account
  and locations involved in the reported activity, identifying information and descriptions of any
  legal entities or arrangements involved and associated beneficial owners, and any information
  about related persons or entities involved in the activity. Financial institutions also should
  provide any and all available information regarding other domestic and foreign financial
  institutions involved in the activity; where appropriate, financial institutions should consider
  filing a SAR jointly on shared suspicious activity.30

  Inclusion of Technical Cyber Indicators: When submitting a report pursuant to this alert, financial
  institutions should include any relevant technical cyber indicators related to cyber events and
  associated transactions within the available structured cyber event indicator fields on the SAR
  form or as part of the attachment field. Any data or information that helps identify the activity
  as suspicious can be included as an indicator. Examples include chat logs, phone numbers,
  and social media usernames used by the scammer; suspicious email addresses; type of virtual
  currency and digital assets involved; virtual currency and / or digital asset addresses and
  transaction hashes native to the blockchain(s) involved; apps used; and the URL, domain, and
  IP address of the service the victim was instructed to deposit into.

                              Other Relevant BSA Reporting Requirements
  Financial institutions and other entities or persons may also have other relevant BSA reporting
  requirements to provide information in connection with the subject of this alert. These include
  obligations related to the Currency Transaction Report (CTR),31 Report of Cash Payments
  Over $10,000 Received in a Trade or Business (Form 8300),32 Report of Foreign Bank and

30. See 31 CFR §§ 1020.320(e)(1)(ii)(A)(2))(i), 1021.320(e)(1)(ii)(A)(2)), 1022.320(d)(1)(ii)(A)(2), 1023.320(e)(1)(ii)(A)(2)(i),
    1024.320(d)(1)(ii)(A)(2), 1025.320(e)(1)(ii)(A)(2), 1026.320(e)(1)(ii)(A)(2)(i), 1029.320(d)(1)(ii)(A)(2), 1030.320(d)(1)(ii)(A)(2).
31. A report of each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to a finan-
    cial institution that involves a transaction in currency of more than $10,000. Multiple transactions may be aggregated
    when determining whether the reporting threshold has been met. See 31 CFR §§ 1010.310-313, 1020.310-313, 1021.310-
    313, 1022.310-313, 1023.310-313, 1024.310-313, and 1026.310-313.
32. A report filed by a trade or business that receives currency in excess of $10,000 in one transaction or two or more relat-
    ed transactions. The transactions are required to be reported on a joint FinCEN/Internal Revenue Service form when
    not otherwise required to be reported on a CTR. See 31 CFR § 1010.330; 31 CFR § 1010.331. A Form 8300 also may be
    filed voluntarily for any suspicious transaction, even if the total amount does not exceed $10,000.
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  Financial Accounts (FBAR),33 Report of International Transportation of Currency or Monetary
  Instruments (CMIR),34 Registration of Money Services Business (RMSB),35 and Designation of
  Exempt Person (DOEP).36 These standard reporting requirements may not have an obvious
  connection to illicit finance, but may ultimately prove highly useful to law enforcement.

                                         Form 8300 Filing Instructions
  When filing a Form 8300 involving a suspicious transaction relevant to this alert, FinCEN
  requests that the filer select Box 1b (“suspicious transaction”) and include the key term “FIN-
  2023-PIGBUTCHERING” in the “Comments” section of the report.

                                               Information Sharing
  Information sharing among financial institutions is critical to identifying, reporting, and
  preventing pig butchering and related activity. Financial institutions and associations of financial
  institutions sharing information under the safe harbor authorized by section 314(b) of the
  USA PATRIOT Act are reminded that they may share information with one another regarding
  individuals, entities, organizations, and countries suspected of possible terrorist financing or
  money laundering.37 FinCEN strongly encourages such voluntary information sharing.

                                           For Further Information
Questions or comments regarding the contents of this alert should be sent to the FinCEN
Regulatory Support Section at [email protected].

            The mission of the Financial Crimes Enforcement Network is to safeguard
            the financial system from illicit use, combat money laundering and its
            related crimes including terrorism, and promote national security through
            the strategic use of financial authorities and the collection, analysis, and
            dissemination of financial intelligence.

33. A report filed by a U.S. person that has a financial interest in, or signature or other authority over, foreign financial
    accounts with an aggregate value exceeding $10,000 at any time during the calendar year. See 31 CFR § 1010.350; Fin-
    CEN Form 114.
34. A form filed to report the transportation of more than $10,000 in currency or other monetary instruments into or out
    of the United States. See 31 CFR § 1010.340.
35. A form filed to register a MSB with FinCEN, or to renew such a registration. See 31 CFR § 1022.380.
36. A report filed by banks to exempt certain customers from currency transaction reporting requirements. See 31 CFR §
    1010.311.
37. See FinCEN, “Section 314(b) Fact Sheet” (Dec. 2020).

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