We have a customer who owns several restaurants in our area. All are assumed names under a single corporation, so their transactions are aggregated, and often lead to CTR filings.
A little over six months ago, we found that this customer met all the criteria for a CTR exemption, and we were preparing to give them one. Literally, right before we exempted them, the owner brought $20,000 to the bank as asked the teller to complete 4 deposits of $5,000 each into the corporation account, so the money could not be "traced." (And yes, a CTR was still filed, because the guy was not a very good structurer)
A SAR was filed for structuring and we have continued to monitor the accounts in the time since we filed. All activity in the accounts before, and since, the day the structured deposits were made is exactly what you would expect for restaurants.
My question is this: does this single suspicious transaction prohibit me from exempting this customer from CTR filings? Because their activity before and since that transaction has been completely normal, I am leaning toward exempting them, with an explanation in their file of how and why I decided to do so, and on the provision that the customer does not engage in future suspicious activity.