Consumer customer wants to exchange "old" $20s for "new" $20s. (Assume >$10K)

1. Since this exchange is for the same denomination, does it have to be reported on a CTR?

2. Would we need to run it through the customer's account?

(Eccentric, yes...we do not consider it SAR territory)

1. Yes. You would report the same amount for cash in and for cash out and select currency exchange in Part II.

2. No, and you would not need to list the customer's account in Part I.

In the BSA/AML Exam Manual under CTR--Overview, Aggregation of Currency Transactions, the types of transactions "include, but are not limited to, denomination exchanges..."

I'm getting push back that exchanges of the same denomination (in this case, $20s for $20s) should not be aggregated and do not need to be tracked.

Anytime currency more than $10,000 comes into or goes out of the bank, no matter what the form or denomination, requires aggregation. Whoever is pushing back is just being a little clueless as to the basics of CTR reporting.

The revered Manual inserted the word "denomination." The regulation does not. Your bank needs to comply with the regulation, not "the Manual;" a currency exchange is simply a reportable transaction.

Put a live CTR on the screen. Post the entries. (The report will not ask for the denominations.) If the report includes them in the math (it will) I'm not certain how the doofus who is disagreeing with you can say they are not reportable.