I'm confusing myself this morning! We have an exempt customer that came in yesterday with cash for a currency exchange. Later in the day they returned with a check which was cashed and is listed as "Change Order Check". Is this CTR reportable? On the one hand it's a negotiable instrument cashed and is exempt, but on the other hand it is a currency exchange and CTR reportable when combined with the earlier transaction. Secondly, it is an entity, so the person that actually cashed the checks conducted transactions over $10,000, so I would need to file on her as conducting on another's behalf,correct?

Knowing the amounts would make it easier to be certain, but assuming it's a phase II exemption, any withdrawal is excluded from your determination of whether a CTR is necessary. The exchange is not.

Thank you Ken!I felt I was over thinking this and going further and further down the rabbit hole:)

Have a great weekend!