OK, my boss insists that there is another way to verify whether a CTR is required other than using a large cash transaction report. Other than relying on your front line staff, you still have to have a catch all method for aggregate transactions and those that occur and different branches. Boss thinks that this can be too burdensome to maintain all these reports. What else is there??

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...my boss insists that there is another way to verify whether a CTR is required other than using a large cash transaction report.

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This late on a long Friday, I would suggest a little reality based therapy for your boss. (I think I used to work for him - he thinks the only thing he needs to prove a point is insistence, right?)

You have to have some mechanized way to aggregate, not because the law requires it, but because you cannot conduct an effective independent examination with out it. Judging by their exam procedures, the FDIC expects you to have something:

16 Review a sample of completed CTRs, whether hard copy or from computer-generated filings, to determine that:

16A CTRs are completed in accordance with Internal Revenue Service instructions and are filed accurately and completely within 15 calendar days after the date of the transaction (25 days if magnetically filed).

16B CTRs are filed for large cash transactions identified by tellers' cash proof sheets, automated large currency transaction system, or other type of aggregation system that covers all relevant areas of the bank, unless an exemption exists for the customer.

From your proof system, you capture all information from cash-in and cash-out tickets plus all data from their offsetting entries. From that data set you remove "look alikes" (tellers used cash tickets when no cash actually walked through the door.) Aggregate what's left by account number of the offsetting entries. Investigate and remove false positives (aggregate cash out for payroll accounts, for example.)