Correct on point one - a CTR would be needed for the scenario in the first paragraph.
Exemptions are never based upon the person conducting the transactions because they relate to the business and its activity, not to the runners, employees, agents, etc. If three businesses frequently use one conductor to withdraw cash for payroll purposes, with Business X frequently withdrawing $15,000, business Y frequently withdrawing $8,000 but never more than $10,000 and business Z frequently withdrawing $7,500 but never more than $10,000, only business X could be considered for an exemption.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8