If the bank received more than $10,00 in cash for payment on behalf of a credit card customer, a CTR would be filed on the customer. Internal cash transfers are not reportable. I.E., you don't report the main vault when they sell cash to a branch.
If they are a wholely owned sub, I do not believe that changes anything. If they are true affiliate, you could exempt them under Phase I if the affiliate was a bank as defined in 31 CFR 103.11(c).
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