I would say yes simply because the customer walked out of the branch with $10,040 in cash and because the $40 was an actual transaction that was handled by a teller. So even though he brought in $600 cash, he got $40 cash back from that transaction (I assume he didn't have any $20 bills and this is why he made such odd transactions.) So he made 3 transactions which, put together, triggered the need for the CTR.
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CRCM + CAMS = certified compliance nerd
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