Skip to content
BOL Conferences
Thread Options
#1595807 - 08/24/11 04:22 PM Reportable CTR?
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
We have joint account owners that the wife withdrew $6,000 from a deposit. Then later that day, the husband cashed a check out of the same joint account for $6,000. Should these two transactions be combined to reach the $10,000 reporting threshold to file a CTR? I know that it would be with a deposit because since the account is a joint account we are assuming both parties benefit from the transaction. However, on this particular instance, since each party withdrew $6,000 we are not sure who benefits from the transactions.

Thank you

Return to Top
BSA/AML/CIP/OFAC Forum
#1595885 - 08/24/11 05:53 PM Re: Reportable CTR? 3up3down
KTW327 Offline
100 Club
KTW327
Joined: Mar 2011
Posts: 183
In the trees
The response I have always received is no- you would not file unless you were told that the funds were to benefit both account owners.

I would research this more though to determine if they were structuring the transactions. It seems odd, but there could be a legitimate reason.

Return to Top

Moderator:  Andy_Z