The OCC was recently in our institution and asked if we are "actively" reviewing CTRs filed for suspicious activity. We are unsure of what specifically they are telling us we need to do. We do look for multiple deposits or withdrawals which appear structured.

Any ideas ?

CTRs can be helpful in developing patterns of cash activity that might trigger further investigation. For example, if you created a spreadsheet or other database of the CTRs you file, and sort it down by TIN, you might see some patterns that suggest further inquiry is needed.

Suppose that you came up with a pattern of weekly CTRs for a household account. Most households don't trigger CTRs on a weekly basis. What's unique about this customer?

Or a pattern of CTRs for a convenience store shows that it has started making regular cash withdrawals. Does this suggest the C-store might be cashing checks? Or perhaps they've installed a "you stock it yourself" ATM? You'll want to know the "why" of the cash withdrawals to decide if the C-store's actions are suspicious.

Or a local charity is regularly depositing cash in CTR-able amounts. You look into other activity for the firm and see outgoing wire transfers that weren't appearing before, or a pattern of checks issued to one party in amounts similar to the cash deposit amounts. Scrutiny of the paid checks reveals they are being processed in countries in the Middle East or in Colombia.

It's a valid recommendation/requirement.