Armored Car Service (Courier Service) is contracted by a number of customers to make deliveries to the bank.

We've been completing the CTR with each customer as the person on whose behalf the transaction was conducted-2c, and the ACS-Courier Service as the Courier Service (Private)-2d.

Two questions:
The courier service makes one delivery a day with the deposits of all customers; I'm presuming we only do ONE CTR with multiple Part Is and not multiple CTRs (one for each customer); is this correct?

In terms of aggregation, if the total that the Courier Service is depositing is over $10,000, we list all customers, regardless as to whether or not their deposit is over $10,000. Is this correct or should we be reporting only those over $10,000.

Example;

Customer A $5,000
Customer B $20,000
Customer C $30,000
Customer D $2,000

The total would be $57,000, which would be the total of the CTR and the total for the Courier Service.

Go back and review FIN-2013-R001, http://www.fincen.gov/news_room/rp/rulings/pdf/FIN-2013-R001.pdf

When the ACS is acting on instructions from the customer(s) or a third party (and not from the bank), aggregation is done by customer, not by conductor.

And a separate CTR is filed for each customer on whose behalf transactions with more than $10,000 in currency are conducted (including those made by the ACS and those made by other means). When identifying the conductor of the ACS-delivered transaction, the ACS (not the ACS employee) is identified.

In your scenario, Customer B and Customer C would have CTRs. Customers A and D would not, unless they had other cash transactions the same day.

Thanks John. I was reading the follow-up one in 2014 and couldn't find the aggregation rule.

One thing to be careful of -- in your OP you used "Armored Car Service (Courier Service)." Note that the "exceptive relief" in the 2013 guidance only applies to Armored Car Services operating under the direction of the customer or a third party. A courier service that isn't an armored car service would not qualify.

Right. I used both, but meaning that the courier service contracted by the customer uses an Armored Car, as opposed to the use of the Armored Car (FI contract). Thanks!

When you say "aggregated by customer, do you mean business entity or business owner? What if a business customer owns several entties, none of which have been deemed to not operate independent of each other or their common owner, and privately contracts with an ACS to pick up currency deposits from each business location? Are these aggregated?

Customer means entity unless the common owner isn't operating them independently of one another. So if LLCs A, B, C, and D have common ownership, and they each send in a $3,000 cash deposit with the ACS engaged by the owner of the LLCs, there is no aggregation and no CTR. If one of the LLCs has two deposits totaling $12,500 in cash brought in by the ACS, you aggregate those two deposits and file, listing the ACS (not its employee) as the person conducting on behalf of the LLC. and the LLC as the person on whose behalf the transactions were conducted.