Okay-I have a really silly question? CTR's are only filed for transactions >$10,000 correct? We have a customer withdrawling $10,000 on the dot every other day and I just want to double check that it doesn't warrent a CTR.

Thanks-Jamie

Doesn't require a CTR - but what about an SAR?

Definitely-I have already filed a SAR. I just wanted to make sure that was all I could do.

Thanks for your help.

Just watch out for the possibility that two of the withdrawals overlap on the same business day. Not likely in the scenario you posed, but suppose a Friday after cutover and Monday before cutover? One business day, two withdrawals, $20,000 = > CTR.

Some people are just too slick for words! (Former U.S. president's excepted!)

I'd want to know about ALL currency transactions conducted by this customer--even the exchange of a 10 for two 5s. Since you know that the customer is in the habit of dealing in $10,000 amounts, all it takes is one currency exchange or small cash receipt to kick you over the limit.

Sounds strange to me too. Now's the time to know your customer. I'd get right on top of it.