Reportable or not? Mr. & Mrs. Noncustomer go to one banking center and cash a on-us check payable to both for $3800. Thirty minutes later Mrs. Noncustomer cashes on-us check payable to her for $4300 and within four minutes Mr. Noncustomer cashes on-us check payable to him for $4300 (same location, different teller). These checks were drawn on a title ins trust account. Of course, besides ID, information was not gathered by the tellers at the time of the transactions since the amounts are not reportable separately. Should the amounts be combined for a CTR?

NOT. Mr. Non-Customer's total cash out is $8100 and Mrs. Non-Customer's total is $8100, both under reporting threshold.

I would look at potential structuring though.

I agree. Not only did each person receive a benefit of only $8100, each person conducted only $8100 worht of transactions.

Agreed. And since these are non-customers, you may want to include your customer in your review as well, since that person is responsible for writing the checks in these amounts in the first place.

You aren't in a good position to grill the two non-customers for answers, but I do recommend posing the question to your customer. You can be direct: "We saw three checks on your account cashed by these two payees on the same day, and they appear to be married. Is there any reason you issued your checks that way instead of a single check payable to both of them?"

Thanks so much for the responses! Our team agrees with the non-reportable amounts in the comments above. We were thinking about the two possibly conducting the transactions at the same time and that might warrant adding all three checks. But, it is true that neither individually benefited from a reportable amount. We've moved on to investigating the suspicious parts of the situation--and, the list of issues surrounding the transactions is growing! Are we having fun yet???

Structuring is probably a given here. You would file a SAR versus a CTR.