We are looking at contracting with a foreign currency provider. I see that they file CTRs for individuals that buy/sell greater than $10,000 in foreign currency.

We would be client of the FC company and our branches would order/sell currency for our clients.

They will have an account at our bank and we will collect the money and ACH it to them for buying and they ship the FC to us for customer pickup.

If one of our clients are buying or selling more than $10,000, do I fill out a CTR as well?

And if we had multiple shipments delivered to our branches for different clients, and the total exceeded $10,000, do we also fill out a CTR on the foreign currency provider, since they have an account with our bank? They are 100% MSB so I can't exempt them.

Thanks in advance for your input

bump.