Thread Options
#2259302 - 09/07/21 02:40 PM Multiple Transactions
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 342
Mid-Atlantic
Customer is withdrawing $45,000 from their account. They present three checks for $15,000 each. When filing the CTR, Part I, you would check the box "Conducting on Own Behalf", and then would you...

1. Check the "Multiple Transactions"
2. Leave "Multiple Transactions" blank
_________________________
CAMS
CAFP

Return to Top
BSA/AML/CIP/OFAC Forum
#2259314 - 09/07/21 06:06 PM Re: Multiple Transactions banker1976
ColoradoAML Offline
100 Club
Joined: Mar 2018
Posts: 233
1

Return to Top
#2259318 - 09/07/21 06:29 PM Re: Multiple Transactions banker1976
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,013
Illinois
According to FinCEN CTR FAQ #18, the answer is "It depends."

Generally I see financial institutions treat this one of two ways.
1. If there is a single cash in/out ticket in a single visit, treat it as a single transaction.
2, If there are multiple cash in/out tickets in a single visit, treat it as mutliple transactions.

The idea behind checking "multiple transactions" is to make it as easy as possible for you to locate the source documents a a later date. If you have three seperate cash out tickets for your cashed check and do not check multiple transactions, would you be looking for a single $45K cash out transaction?

As you an see, your answer ultimately depends on your procedures for how these transactions are processed.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top

Moderator:  Andy_Z