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#1984708 - 12/22/14 08:07 PM CTR Filing?
Anonymous
Unregistered

Of course the Monday before going on vacation and I'm having a mental lapse...

Anyway, husband and wife joint on an account. Wife comes in to one of our branches and withdraws $10,000.00 (no CTR trigger), 45 minutes later, husband uses debit card to withdraw $400 from an ATM. This has triggered in our BSA Monitoring software a CTR based on over 10K was withdrawn for the day. I'm not sure how I would report this, if at all.

Help, please? Thank you!!

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#1984715 - 12/22/14 08:33 PM Re: CTR Filing? Anonymous
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
If the husband wasn't with the wife when she withdrew the $10,000, you wouldn't be sure he benefited from the transaction unless she said she was getting the money for him.
In situations like this, if each acted on their own to the best of our knowledge, we wouldn't file a CTR.
But, we would review and try and determine if this was their way of structuring to avoid a CTR.

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#1984724 - 12/22/14 08:57 PM Re: CTR Filing? Anonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
See Question 24 in this FAQ.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1984728 - 12/22/14 09:04 PM Re: CTR Filing? Anonymous
Anonymous
Unregistered

John - I read the FAQ and it has the husband already triggering the CTR with a $12,000 transaction. I'm inclined to agree with NotDoneYet as there wasn't a transaction or aggregate transaction to trigger a CTR filing.

Thank you both for the help!

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