We had a customer come in and deposit $13,500 in cash on Friday. The customer then proceeded to make a Foreign currency purchase, that we had to order from our correspondent. We debited our customers account in the amount of $13,495.74 US for the 11,125 euros and offset the GL account for the correspondent bank. The transaction posted to the account on Friday. The euros are being shipped from our correspondent to us and we will have the customer come in to pick them up when they arrive (today or tomorrow).

How exactly do I prepare the CTR or CTRs? Do I show the deposit on Friday as a deposit or as something else since I know the funds were being used to purchase foreign currency? Do I do 1 CTR or 2 since the actual foreign cash out is happening on a different business day? We have never had a customer order this much in foreign currency so we are in new territory here.

Any help is much appreciated. Thank you!!

My answer would be driven by the business days; i.e. you owe them two CTRs. If you have any doubts, check with the Helpline.

Thank you Ken!

Do you have an opinion about whether the deposit should be shown as a deposit or as an exchange? She deposited the funds into the account, but the funds ultimately were for the purchase of the foreign currency.

There is one piece of FinCEN advice where they want the bank to report the purchase of an official check even if the money was initially deposited. That advice would make it hard to use the CTR as a "tracer" document and would be even more nonsensical if it contemplated the two transactions taking place on different days. I would not say that situation is analogous to yours.

From my perspective, you had a cash deposit one day and a cash withdrawal (albeit in non U.S. currency) the next day. There was no exchange. Even though I'm confident, I would still call the Helpline because my memorandum of that conversation would trump the opinion of any examiner or auditor. This is something I would not want to have to listen to someone ruminate on months later. It happened. We reported it. What's next?