I may be overthinking this but here is the situation that has me second-guessing myself despite my forum profile name :

Note: Husband and Wife come in together during all transactions although not done all at once.

1) Currency Exchange - Indications are they will both benefit
2) Transit Checks Cashed by and payable to husband
3) Account Withdrawal by wife

Husband Total including C/E = $8900
Wife Total including C/E = $3400
Total: $12,300.00 - CTR form generates due to Account/SS#'s being referenced by tellers

I lean toward no CTR because although they were together - we do NOT have knowledge that either of them benefitted from all transactions conducted with the exception of the currency exchange that was just over $2,000.00.

Them both being present is the monkey wrench here. Had they come separately, this would be a non-issue.

Thoughts? Anyone?

Appreciate the feedback!

I agree with the way you are leaning - the bank does not have knowledge that they both benefited from all transactions. They acted separately. No CTR

I'd probably just file rather than trying to document all of this and potentially having to argue it with an auditor/examiner.

"They came in and did the transactions together" sounds like a very simple justification for why you filed, if you were asked.