I am pre-apologizing for posting this, as I have read many other threads with the same types of topics, but I have a somewhat unique situation going on that I need to find an answer to!
I have a joint savings (husband and wife as owners). Wife comes into branch and w/d's $10,000. Later that day, 5 ATM w/d's post to acct, two different ATM cards used each belonging 1 to husband and 1 to wife. Wife's card showing to be used for two $503 w/d's, husband's card showing to be used for 3 other w/d's ($1003, $183, $803). I believe the CTR should only reflect the w/d's I know FOR SURE were done by wife, because husband was not present at time of $10,000 in branch w/d so does not benefit. My co-worker (and a much more experienced banker than I) thinks ALL ATM w/d's should be included, along with husband as beneficiary on CTR, since ATM w/d's were showing to be done by both people at the same places and both may have benefited. Who is right? Any guidance/opionions are greatly appreciated, thank you!!

With Question 24, FinCEN really tried to make this easy so please don't swim upstream on this one.

If the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, then it would neither be required to nor prohibited from listing Jane Smith in a second Part I.

You are entitled to default to listing all parties to the account as benefitting from a withdrawal (as you do on deposits) if you so choose. 5 minutes spent discussing the alternatives is 5 minutes wasted.

Thank you, I just wanted to be sure that I would not be penalized for including all of the information, and that makes it pretty clear I would not.

The only thing I can add to this discussion is to take care in reporting the ATM transactions. It seems pretty obvious the amounts include a non-cash fee which should not be included in the CTR amounts.