Do we add ATM withdrawals in the aggregate amount of a day's activity for BSA purposes. For example, a customer cashed a check for $9900 and later in the day makes an ATM withdrawal of $200. Is this $10,100 in withdrawals for the day and we file a CTR? Definitely would review for suspicious activity reporting.

A CTR is necessary, and probably a SAR. It looks like the customer structured the transactions to evade being reported. If this is ML, it's a strange type. Structuring is a way to sneak the dirty cash into the banking system, not out of it.

Sounds like we're raising the bar on aggregation systems here! I am not aware of any automated system that will incorporate ATM cash withdrawals with other the counter withdrawals. Are you manually aggregating because the customer came so close with the OTC withdrawal?

Thank you for your responses.

This is a hypothetical. We had an outside auditor ask us if we aggregated ATM withdrawals. I had never thought about it.

No we can't incorporate ATM withdrawals in our automated system it would have to be manual. However, we have a $200 a day withdrawal limit, so I'm not too worried about it. I guess we'll check cash transactions in the $9800 - 10,000 range, which would be checked for suspicious activity anyway.

Don't worry about this type of transaction because it won't happen in the real world. You're only required to report what you know and not required to make extensive efforts to hunt for aggregates. Of course, if you have an aggregation system in place, you can not choose to ignore it.