We had an employee withdraw a CTR reportable amount of cash from an internal GL account to give out as employee bonuses. Is this transaction CTR reportable?

My first reaction is no because the transaction was on behalf of the bank.

Thanks!

I remember reading something similar to this a while back and managed to dig it up, you might find this thread useful...

Previous Thread

Thank you for the Previous thread!

If I were you, I would be contacting FinCEN for an official interpretation, and document their response.

Why? It is no different than the head teller debiting the vault's G/L account and getting cash for delivery to one of the other tellers in the bank.

Just make sure these cash bonuses get into the employee's W-2s

I guess you could say I am a little paranoid