Husband and wife come into the bank to open new accounts, with each account with a single owner (husband is sole owner of his and wife is sole owner of hers). I am sure that they came into the bank together. Each account is opened with $9,600 in cash. The branch does not think that a CTR is in order while I do. What do you think? I will also file a SAR.

I would not file a CTR because the cash did not exceed $10,000 by or on behalf of the same individual on the same business day. However, if you feel there may be suspicious circumstances surrounding each of the transactions, such as structuring, then I would file the SAR.

Did each spouse conduct their own transaction, or did one person conduct both? Thi is the question you need to answer to determine the CTRworthiness of the transactions.