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#2178546 - 05/17/18 04:01 PM CTR or no CTR?
Compliance Novice Offline
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Joined: Sep 2003
Posts: 22
Our daily Currency Transaction by Tax ID report indicates a total cash out of $10,660 for a particular customer. It was determined 2 accounts were affected. The one is owned solely by the husband, the other is a joint account. He withdrew from his sole account $5,660 and she withdrew from the joint account $5,000 at the same branch. This came to my attention during an audit of our BSA software; it did not pick up these as requiring a CTR. [The daily report uses his SS# to aggregate the transactions] Since we have knowledge 2 different people conducted the transactions, and he did not perform both, is the software correct that no CTR needs to be filed?

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#2178554 - 05/17/18 04:29 PM Re: CTR or no CTR? Compliance Novice
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
Did it happen in the same visit...were they together? If you have no knowledge that he benefitted from the joint account withdrawal made by her, no CTR. This would have generated a call to the branch for us though. Our core would not have generated a CTR, but we have a report off our BSA software we use for reconciliation and that report is blind to conductor and would have identified a possible CTR. Our CTR analyst would have reviewed the time stamps and probably called the branch for info on the purpose of the withdrawal to make a determination of who benefitted.

It is possible they were structuring also, if the visits happened at different times. A review of source of funds might shed some light.

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#2178579 - 05/17/18 06:20 PM Re: CTR or no CTR? Compliance Novice
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Your software doesn't know they are married. You are only confused because you do...

No CTR.
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