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#1164239 - 04/15/09 10:31 PM Aggregation of Currency Transactions
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
If a customer brings in cash, deposits it into his/her account and then immediately wires it out, should the amount of that wire be included in the Aggregation of Currency Transactions Report?

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#1164240 - 04/15/09 10:32 PM Re: Aggregation of Currency Transactions Norrie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,279
Galveston, TX
No - the wire is not currency.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1164243 - 04/15/09 10:42 PM Re: Aggregation of Currency Transactions rlcarey
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
But wouldn't that be a good way to launder money? The customer could deposit $20,000 and immediately wire it out and it now looks legitimate. Also, it won't require a CTR since it's not considered a cash transaction.

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#1164246 - 04/15/09 10:47 PM Re: Aggregation of Currency Transactions Norrie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,279
Galveston, TX
You need a CTR for the $20,000 - you said: "should the amount of that wire be included in the Aggregation of Currency Transactions Report". I guess I misunderstood.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1164318 - 04/16/09 12:36 PM Re: Aggregation of Currency Transactions rlcarey
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
May be something you file a SAR on. I would watch the account/customer and apply CDD/EDD procedures.
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David Dickinson
http://www.bankerscompliance.com

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