I have recently transferred into the compliance area of small community bank. I have focused most of my attention of BSA during the past month. In the absence of automated systems I have been reviewing months of account activity. In a review of account debits I noticed that debits were being cashed out for $10,000. That would be OK but I think there is a chance that multiple debits of $10,000. were cashed out by the same individual- different account holders, commercial accounts- during the same business day. If this turns out to be the true situation I have, what should I do about the past missed CTRs. Do I begin filing at this time? Do I complete SAR for possible structuring? Any suggestions would help.

You will need to call the Detroit Computing Center for guidance. They can instruct you on any back-filing that needs to be done or tell you to begin filing on current transactions. It is always wise to request guidance from them in writing for your own protection and to show to examiners when they undoubtedly ask you for the documentation.