Hello,

I can't seem to work this out today. I need help folks

Husband and wife walk into a branch. Each have separate Certificates. They each pull just under 8K.

Half of management says file as they were together the other half says no file as they are not linked accounts.

An answer is great a reg quote would be even better. I owe this site partial salary at this point. Thank you in advance!

Refer to FAQ 24:

https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr

Regardless of whether you choose to file a CTR or not, you have a SAR decision to make for structuring.

Thank you Rlcarey you are always quick to reply. I do have one follow up which I think is what is throwing me off and I should have typed it in the first place to waste less of your time.

The husband and wife are not connected by their accounts in anyway. They keep all of their assets separate so would this change your answer at all?

Thank you Rlcarey you are always quick to reply. I do have one follow up which I think is what is throwing me off and I should have typed it in the first place to waste less of your time.

The husband and wife are not connected by their accounts in anyway. They keep all of their assets separate so would this change your answer at all?

Not for the filing of the CTR, which would be based on the fact at hand and filed based on the FinCEN FAQ. Only you can make a business decision about a SAR filing based on the transactions, historical account information and any other facts present.

If the husband and wife are not linked on accounts, jointly, there is no obligation to fill out a CTR.

Personally, I would not fill out a SAR. Large cash withdrawals, in this climate especially, are not uncommon.

I would not fill out a CTR or a SAR since they are not linked on the accounts.

You cannot make a SAR judgement without all the facts. If you are doing that in your bank, good luck. Who knows what else might be going on with these two customers, beside the bank at which this occurred?