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#2276874 - 10/20/22 07:23 PM CTR Question
Bonkers for BSA Offline
Member
Joined: Oct 2015
Posts: 83
I need help because I've thought about this too long and am making it way more complicated than necessary. What I want to know is if a CTR is necessary.

Joint personal account with John Doe and Greg Doe. Transactions occurred on the same business day out of the same account.

Greg Doe withdrew $2K at 2:15PM.
John Doe withdrew $8K at 3:45PM.
Greg Doe withdrew $500 from ATM at 5:30PM.

Greg withdrew a total of $2,500 that day. John withdrew a total of $8K that day.

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BSA/AML/CIP/OFAC Forum
#2276876 - 10/20/22 07:31 PM Re: CTR Question Bonkers for BSA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
No CTR, but consideration on a SAR for structuring might be appropriate.
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#2276882 - 10/20/22 07:47 PM Re: CTR Question rlcarey
Bonkers for BSA Offline
Member
Joined: Oct 2015
Posts: 83
We only aggregate the transactions like this situation on deposits, not withdrawals?

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#2276886 - 10/20/22 08:00 PM Re: CTR Question Bonkers for BSA
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
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