Two different individuals cashing checks under $10,000 for a business - two separate times during the day. Aggregating amount is over $10,000. CTR on business only?

Were these payroll checks, petty cash checks...?

The transactions would only be aggregated if they were both conducted on the business' behalf. Two separate individuals cashing payroll on their own behalf would not be aggregated.

One petty cash the other is for payroll purposes.

Payroll, as in one was a paycheck or the individual was getting cash for the business to pay the business employees?

One was for payroll - to pay business employees in cash; the other was petty cash - "pay for supplies". Two different people.

Okay - so basically both checks were for the business to use, so you would combine the transactions and file a CTR. It would be different if one was a paycheck to an employee who cashed the check for his/her self and then the other check was simply petty cash for the business.

Having said that, it's stuff like this that shows how antiquated the entire CTR filing process is. It takes more time to complete a CTR than it does to complete a 1040A tax return. The process needs to be brought up to date for banks to file, on a monthly basis, a report of all cash-in and cash-out transactions per account, above a pre-selected aggregate amount. The whole notion of "conducted by" and "conducted on behalf of" is just noise. It would be the one potential useful result of the whole Beneficial Owner mess - the report would include account number, account name, physical address, TIN, and Beneficial Owner and Control Person information.

Then LE can comb the database to their hearts content looking for aggregate activity across multiple institutions (because let's face it, the more sophisticated criminals will run money through various institutions, not just one) and then institutions can focus their resources on CDD/EDD and monitoring activity rather than the painful exercise of which friggin' box to check on a CTR.

Sounds like the business is receiving all of that cash so I would file a CTR based on the info provided.

Ahh looks like Princess beat me by a few seconds.

Couldn't agree with you more.

Different question here.
I believe the answer is no we don't file a CTR but I have noticed where a few were filed in the past.
Customer comes into bank and withdraws $10,000 cash. He later goes and withdraws an additional 400 at a foreign atm (now owned by us). Our AML software adds this activity together and wants to file a CTR, should it?

Thanks in advance!

You have knowledge that a customer withdrew 10,400 through your institution and ATM. I'd file a CTR.

Oops I just realized that I had a spelling error on my original post and said now owned by us but it should say not owned by us. Does that make a difference to you bcompliance?

Makes no difference. I read it as "not" the first go-around. If you know of it, you report it.

Got it. Thanks.