I hope this isn't a stupid question, but if I have a customer with a CTR Exemption, are that customer's US to US currency exchanges covered by that exemption also? The customer frequently exchanges larger bills for smaller ones. I understand the need to consider the possible SAR "red flags" associated with it. But I'm not sure if I need to file a CTR for the exchange if it's over $10k?

Phase I customer would be exempt from CTR filing. Phase II customer - not so, CTRs are required for currency exchanges.

Also, exchanging small bills for large (not your situation) is more frequently connected to money laundering or the drug trade. It's something of a mystery why the new SAR suggests exchanging large bills for small is of equal interest...

Thanks for the help guys! Will be sure to continue actively monitoring for exchanges on Phase II's.