United States v. Bank of New England, N.A.

BOWNES, Circuit Judge.

The Bank of New England appeals a jury verdict convicting it of thirty-one violations of the Currency Transaction Reporting Act (the Act). 1 31 U.S.C. §§ 5311-22 (1982). 2 Department of Treasury regulations promulgated under the Act require banks to file Currency Transaction Reports (CTRs) within fifteen days of customer currency transactions exceeding $10,000. 31 C.F.R. § 103.22 (1986). 3 The Act imposes felony liability when a bank willfully fails to file such reports “as part of a pattern of illegal activity involving transactions of more than $100,000 in a…