I already know everything that went wrong with this - but looking for how to complete the CTR.

We have a customer who is an armored car service. They normally deposit money into a mutual customer's account on that customer's behalf.

They recently decided to conduct a currency exchange for a non-customer. They exchanged over $10k for Marijuana Co LLC (name changed obviously - but you get the idea). No money went through their account, they are the conductor, the Marijuana LLC the beneficiary.

So our software system is freaking out & won't let us tie anything together without an account number & saying the Armored Car customer benefitted somehow. Can we just complete this CTR manually through the BSA EFiling system & call it a day?

I'm thinking Marijuana LLC as Beneficiary - transactions conducted by a Courier (private) (since this AC is not contracted by the bank). Currency Exchange - $XXX .... Boom.

Yes. As for how to complete the CTR I suggest you call the Helpline, not because you cannot figure it out, but because no matter how you do it any reviewer could criticize it.

Make certain you have some internal controls on access to discrete filing; you don't want it used when you were not involved in the decision.

Thanks! I like the idea of documenting a call to the HelpLine. Appreciate your help Ken.