I've been struggling with this question for some time now and decided to ask the communities opinion on the topic.

We have a MSB customer (not necessarily relevant but provides context for the withdrawals) that makes multiple cash withdrawals from their account on any given business day to fund their check cashing operation.

Obviously both the Business and Employee(s) conducting the transactions are to be included in the CTR filing but my question involves when to begin attributing cash to each transactor on Line 22-Cash Out For Individual/Entity Listed On Line 4.

For example;
Business Employee A conducts a $5,000 cash out transaction at 5:00PM on Monday night at Branch 1 (Tuesdays credit date). Note; a CTR is not triggered for this transaction.

Business Employee A conducts a $10,000 cash out transaction at 10:00AM on Tuesday morning at Branch 1 triggering a CTR transaction.

Additionally, lets pretend that 2 different tellers were involved in processing the transaction.

In the absence of any additional information the completing Teller would attribute $15,000 to the Business and $10,000 to Employee A under each of their respective Line 22 entries. Thus "leaving" $5,000 unattributed to an actual individual as the transaction occurred before the Bank knew a CTR needed to be filed.

Of course, the Bank would have record of such information (posted history>retrieve image>note name of Employee who endorsed check) but at least in our case this would require manual research after the CTR is created to obtain such information.

How would you complete the CTR? List only transactions occurring after a CTR was prompted? Or assign all cash withdraws to an individual no matter the circumstance?

I've been following the "keep track after a CTR was prompted" method as that is how we report Cash In deposits resulting in a CTR (i.e. don't care about the person getting $20 in change on Friday after 4PM but when the CTR is prompted at 8AM on Monday then all subsequent transactions are tracked and attributed correctly).

...as an aside we've recently went through both an audit + exam and nothing was said but that doesn't necessarily mean anything.

If you have "knowledge" that employee A conducted the transaction on Monday night, you have to allocate that deposit to that conductor.