So the customer writes a check against the account and then deposits it right back in for cash? I'm very confused... Is there a delay in the timing for withdrawal and redeposit?
If there is a delay in timing to me this isn't a CTR, but a SAR with pretty strong leaning towards classic money laundering...
For me the scenario plays out like this... Pablo Escobar wants a front for his drug business. He uses cash, he needs cash, he wants to earn interest on his cash not in use. He starts a company in the name of Ramon Escobar called NottaDrug Front, LLC. The customer doesn't do business in cash, but is a legitimate company. Pablo brings him cash to deposit... which he does and in return he gives Pablo the cash from the account by sending the runner (hoping you won't file a CTR, but if you do its against the business and you have the runners info further hoping it goes unnoticed). This way, Pablo's dirty money ends up just clean and dandy in the bank... and ready for him to access whenever the FBI/ATF/DEA come for him.
If there is not a delay, then I have no earthly idea why somebody would go through this excercise except boredom or to start to establish a pattern of activity so that they can later begin doing suspicious stuff.
To answer your question, the use of a runner doesn't mean that a CTR shouldn't be filed. We have a similar situation with a customer of ours, but the money leaves the bank and doesn't return in cash, so it is slightly different... I would say file a CTR if it is over the threshold and the money physically leaves the bank for any length of time.
In life, there is a lot less that could get better and a lot more that could get worse.
MBA Fin/MBS HR
My views only!