We have an ongoing discussion on how to fill out this CTR. We have this scenario happening more often. John Doe has a sole-proprietorship MSB. He cashes a negotiable $16,611.00 and Sally Smith, another employee cashed a check for $28,160.00 for the MSB. At the same time, John Doe works for ABC Inc. He brings in cash deposits of $10530.00 for ABC Inc. and has a currency exchange for ABC Inc. for $1700.00. I need to know what to put for each person in items 21 & 22. I think we need to list the cash-out for ABC Inc. for $1700.00 even if it under the $10,000.00 to show the distribution of the funds.

Since all the cash-in transactions conducted by John Doe add up to more than $10,000, and all the cash-out transactions conducted by John Doe add up to more than $10,000, they all should be included on the CTR. (That would include the cash in for the currency exchange and the cash out for the currency exchange.) [Of course, Sally's transaction would be included as well.]

So the ABC Inc. should have a cash-out of $1700.00 listed with their account number, even if their total is under $10,000.00

I believe so - perhaps someone else has a different opinion. In any event, you'll already have a cash in enty in Item 21 for ABC Inc's Part I for the deposit + cash in part of the currency exchange - $10,530.00 + $1,700. The cash out amount should be entered in item 22.

The only opinion you can bank on is FinCEN's. Call the helpline, explain the scenario, document what they tell you, and call it a day.

The cash out is part of the transactions conducted by John Doe, whose cash outs exceed $10K. It gets reported because he conducted the transaction, not because it's part of the ABC Inc transactions.

If you or I brought in the ABC Inc transactions, only the cash-in side would be reported on the CTR. The cash-out side of the cash exchange would be ignored.