When we have multiple small deposits for the same business in one day that total over $10,000, our BSA team is having each branch where the transactions occurred provide conductor information for each deposit, even though none of the deposits total over $10,000 individually. I've challenged this process, and the concern that is raised is that if stop doing this, we will not be able to review activity at the conductor level in the instance the same person couriers deposits for multiple businesses.

I certainly don't want to create a gap in the program, and I think this is a risk-based decision. Is any other bank doing this? Or are we just going above and beyond what is required?
Thanks

There is no requirement to collect conductor information for transactions under the reporting threshold, hence the aggregated transaction box on the CTR form. Many banks have elected to collect this information for transactions exceeding a certain dollar threshold but again, that is a best practice. If this is a questionable business or high risk business then you might have different policies on how you treat those customers but this sounds like more work than it is worth. Of course you will find others who disagree.

if i am understanding your scenario, the branches are trying to determine who conducted the transaction now that you know due to aggregation it is reportable - i was taught not to jump through hoops for conductor information, if you have knowledge that say it was Susie Q who brought in "X" then you could add the information you have on her.
i guess my team knows there are certain businesses who will - after aggregation - have a reportable transaction and that the conductor is typically the same one or two people so then we have their info on file IF IT WAS one of them.

this is why the CTR forms have the options of multiple and aggregated

Thanks to you both. In general, it sounds like you don't collect the conductor information on a single transaction unless that one transaction itself is over $10,000. Appreciate any feedback we can get on this practice.

Thanks!

We reach out if we have common timestamps or tellers that exceed the limit to see if we have a common conductor that they could or should have identified and failed to report. Otherwise we use the aggregated transaction option as others suggested.