If examiners see that transactions are falling through the cracks when a bank isn't using features in its systems that can detect them for aggregation, a bank should expect to at least get admonished to start using the tools in their toolkits to inform their CTR filings. It can depend on what's getting missed (missing routine "pocket-money" ATM withdrawals isn't usually a big deal, but missing a conductor making three $5000 cash deposits to three separate businesses in the same teller visit is a really big deal) and the cost of beefing up training and/or systems to eliminate those cracks.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8