A customer makes a $100 ATM withdrawal on a Saturday, which posts to the account on Monday. That Monday, the customer makes a $10,000 cash withdrawal, which posts to the account on Monday. The customer then makes a $100 ATM withdrawal on Monday but after the cut-off time (5PM) for the business day, which posts to the account on Tuesday.

What amount should the CTR be filed for?

I'm calling FinCEN in the morning for guidance.

You should aggregate the Saturday ATM withdrawal and the Monday withdrawal so the CTR would be for $10,100. The after 5 ATM withdrawal posts on Tuesday so would not be included. You should also be suspicious of why the customer conducted the transactions in this manner.

devsfan,

FinCEN aggreed with you. I guess I'm finding it hard to understand that we have knowledge of the customer making a cash withdrawal and an ATM withdrawal on the same day which aggregated over $10,000.

If we apply the same guidance to a customer who makes an ATM cash withdrwal for $50 at 5:15 PM on a Friday (after the cut-off time for ATM transactions) and then parks their car and comes into the banking center at 5:20 PM and makes a $10,000 cash withdrawal, we wouldn't file a CTR becasue the $50 ATM withdrawal would post the next Monday, while the $10,000 would post on that Friday. Chronologically they occurred in reverse order to how they posted to the customer's account.

That is also correct. Each bank establishes its own business days. If the transactions occurred on the same business day and the bank knows about them, they are subject to aggregation. If they occurred on the same calendar day, but different business days according to the bank, they are not subject to aggregation regardless of whether the bank knows about them.

They needed a rule that would spawn consistency and this one does.