I have a question regarding timing of ATM transactions and CTRs.
1) A customer withdrew $500 from our ATM on Thursday, 4/28 at 4:21pm from her joint account.
2) Her husband withdrew $500 from our ATM on Thursday, 4/28 at 4:22pm from the same joint account.
3) The ATM withdrawals hard posted to their account on Friday, 4/29.
4) The customer withdrew $9,900 at the teller window on Friday, 4/29. We have no knowledge if the husband benefitted from the withdrawal.

Do I include the ATM withdrawal on the date it occurred (no CTR) or the date it posted to the account (CTR)?
If a CTR is required, do I include both $500 ATM withdrawals for the customer total since she was in the vehicle for both withdrawals?

Thank you!

CTRs are based on business day, not calendar day so a CTR is required. Review CTR FAQ #24 to determine whether you include the husband or not based on your knowledge of the purpose of the transactions.

Lastly, determine whether you also file a SAR for structuring.

I was thinking the same thing just wanted someone else to confirm it. And yes, monitoring them for SAR.
Thank you Brian!

"monitoring them for SAR"

FWIW: A SAR could be fled if you believe that the customer structured this one group of transactions.