I think most banks have dollar thresholds for which they search for situations that require CTRs. For instance, a bank might reasonably set $5,000 and up. In our case it's $3,000 and up. We look at cash transactions under $3,000 and use a variety of systems and reports and cross-compare them, going to extreme efforts to locate all possible CTRs.

By chance, we detected that a non-customer performed multiple transactions that could have caused a CTR, but didn't. One of her transactions was under $3,000, and was on a different account than the other one. It's a pretty unusual situation and we think we catch all of these types of CTRs, except, perhaps, non-customers. We're still trying to figure out how this one was missed. But ignore the "why was it missed" angle because I'm not seeking advice or tips about that or how to fix that.

My only question for this thread is: Would you file that CTR, in this situation, even though the CTR will be over a month late? Or would you not file, because it's below the threshold under which your policy requires staff to be checking, and because it's beyond the filing deadline?

If you have knowledge, you should file, If you discovered it, then it is possible that an auditor/examiner might find it. It happens and if it does, you won't want to be in a position to have to explain.

I'm a little puzzled as to why you said you were surprised this was missed. That makes it sound like it should have been included in what you review for possible CTRs.

Generally, in these situations, just be conservative and file the CTR. Then you can sleep at night.

You have a non-customer doing over $10,000.00 in cash transactions in a single day?

Sounds like a SAR should be filed too.

A SAR? Maybe or maybe not. It depends on the facts and circumstances surrounding the transactions. This person may have made three separate deposits in cash for three separate businesses at three different branches, and under circumstances that make the transactions legit and their involvement as the conductor non-suspicious.

Or maybe not, and a SAR should be considered.