Anti-money laundering (AML) compliance is usually seen as a concern for banks, but a little-known federal obligation is catching out businesses far beyond the financial sector, according to Alessa.
Car dealers, jewellers, lawyers, estate agents and travel firms can all face a reporting duty the moment a customer pays more than $10,000 in cash.
Form 8300, the Report of Cash Payments Over $10,000 Received in a Trade or Business, is jointly administered by the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN). The businesses least likely to view themselves as subject to AML rules are often the ones most at risk of missing it.
The obligation applies to any person engaged in a trade or business, whether an individual, corporation, partnership, association, trust or estate. Unlike Currency Transaction Reports (CTRs), which are filed by banks and credit unions, Form 8300 targets businesses receiving large cash sums from customers.
Typical filers include dealers in vehicles, boats, furniture and jewellery, alongside pawnbrokers and legal professionals. Crucially, a firm does not need to be cash-heavy to be caught; a single large payment is enough.
The $10,000 threshold covers a single transaction or multiple related payments. Transactions within 24 hours are presumed related and must be combined, while payments spread further apart still count if the business knows, or should know, they form a connected series.
Cash is also defined broadly. It covers US and foreign notes and coins, plus cashier’s cheques, money orders and traveller’s cheques with a face value of $10,000 or less when used in designated reporting transactions or to sidestep reporting.
Businesses have 15 days from receipt of a reportable payment to file. Where smaller payments later push the total over $10,000, the clock starts when the aggregate crosses the threshold. Since 1 January 2024, firms required to e-file other information returns, such as Forms 1099 or W-2, must submit Form 8300 electronically via FinCEN’s BSA E-Filing System. Filers must also send a written statement to each named person by 31 January of the following year, unless the form was filed voluntarily to flag suspicious activity below the threshold.
Casinos highlight the overlap between regimes: larger operators file CTRs for gaming activity but must still submit Form 8300 for non-gaming cash receipts, such as restaurant or retail spending.
Splitting payments to avoid the threshold, known as structuring, is a federal crime in its own right. Businesses may voluntarily report suspected evasion attempts even below $10,000, though spotting them requires pattern recognition across payments and time.
Because Form 8300 is frequently treated as a tax form rather than a compliance obligation, it slips through the cracks. Firms accepting large cash payments, even occasionally, need documented processes and case management tools that track intake and filing status in one place.
Read the full Alessa post here.
Copyright © 2026 FinTech Global
