Are we required to monitor Internet Bill Payment transactions for CTR reporting?

No.

CTR stands for Currency Transaction Report. There is no currency to report in bill payment transactions.

Ergo, no CTR requirements.

If your reference, instead, were to SARs, I'd suggest that bill payment transactions would form a piece of what one might look at when determining whether a customer's activities seemed suspicious.

First published on BankersOnline.com 04/07/03