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#2098227 - 09/13/16 04:06 PM CTR scenario with exempt accounts
EB, CAMS Offline
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EB, CAMS
Joined: Mar 2009
Posts: 133
flyover country
Customer has c-store business that is phase II exempt for CTR filings. Customer also has personal accounts at the bank. Yesterday customer made a cash deposit to the business account for $10,250.00. In the same visit, he deposits $9,750 cash to his personal account.

My thought is that the CTR is not required because the greater than $10k was deposited to an exempt account. Is that correct?
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#2098244 - 09/13/16 04:57 PM Re: CTR scenario with exempt accounts EB, CAMS
RockChucker, CAMS Offline
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The Country
You might not have to file a CTR but I would look closely into the activity into his account. He might be structuring, also where did the $9,750 come from?
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#2098251 - 09/13/16 05:03 PM Re: CTR scenario with exempt accounts EB, CAMS
EB, CAMS Offline
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EB, CAMS
Joined: Mar 2009
Posts: 133
flyover country
Thanks RockChucker. And yes, we were already onto the suspicious activity angle for the personal account activity, regardless of the CTR filing. We suspect the funds may have come from the business. But I can't confirm that.
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#2098255 - 09/13/16 05:26 PM Re: CTR scenario with exempt accounts EB, CAMS
John Burnett Offline
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Cape Cod
To confirm your thoughts, Frog Lady, because the C-store is exempt, for CTR purposes you ignore the deposit to the C-store account and only look at the other transaction. Since it doesn't trigger a CTR filing, you don't file.

If you start to see a pattern of transactions like the two that prompted this discussion, you should consider ditching the exemption so that you'll be filing on the owner's cash deposits, too. And continue your monitoring for suspect activity.
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