One of our customer's just started using same service so if anyone has been successful with filing the CTRs for this type of service I would greatly appreciate some feedback. Otherwise I am just thinking of starting to exempt these customers to avoid these CTR's because every time we call FinCEN we get a different version with very different suggestions on how to complete the CTR. .

Any recent guidance on handling "indirect" CTRs in a situation like this? For filing purpose, I'm leaning towards using the actual date the courier picked up the currency regardless if the branch is an official bank location. From my experience, the whole process usually takes more than 15 days, as it would be dependent upon the processing bank to credit the "home" bank with a notification. In such a situation, we do end up having a late CTR, which seems to be inevitable. Please advise.