We have a customer that came in and conducted a $34,000.00 withdrawal for a business account that she is a signer on. Later that day her card was used to make a withdrawal of $300.00 from her personal account from an ATM.

Do these transactions need to be aggregated based on common conductor? We know the card assigned to her was used for the ATM transaction, however, cannot be certain it was her.

If the transactions are aggregated, do we check the ATM box or list her as the conductor on the ATM transaction?

Anyone have any ideas?

If you believe the transactions were completed by the same individual, and you have knowledge of the transactions, you must combine them into a single CTR. Check the ATM box to indicate that one of the transactions was at an ATM. Check box 3 to indicate you're reporting multiple transactions. In the Part I record for the individual, check box 2a and combine the dollar amounts and list both account numbers in item 22. If the $34,000 withdrawal was on behalf of the business, create a Part I record with box 2c checked, and include the business account number in item 22.