I’ve read and reread the FAQ’s, particularly #24 and all the BOL threads and I’m having a mental block on personal joint accounts and aggregation for both deposits and withdrawals. Unfortunately, there is no documentation as to presumption of use of cash for my transactions and no documentation the bank “has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day.” I guess, don’t ask, don’t tell.

Issue 1:
Joint account with either husband/wife (mainly) or mom/son (one situation). There are no situations where both accountholders are in the bank at the same time. One party (e.g. wife) will come in during morning hours and make a deposit of over $5,000 (usually $5,500 ranging up to $8,000) and other party (e.g. hubby) on the account will visit the same branch in the afternoon to make another deposit (typically in exactly the same amount ranging from $5,500 up to $8,000). There doesn’t appear to be any attempt to hide the transactions as they are at the same branch and the amounts typically are not that close to the $10K level itself.

Issue 2:
Same as Issue 1 but the transaction are withdrawals, in the morning and afternoon, by differing parties on the joint account and almost always in exactly the same amount which aggregate to between $11,000 to $16,000. However, there is one situation where the husband withdrew exactly $5,000 in the morning and ditto for the wife in the afternoon. Structuring???
All of the accounts above are personal accounts. Complicating, I think, this issue is that one of these accounts might be for the owner of a beauty shop and a substantial amount of the deposit could be presumed to have been earned through the business.

Thanks in advance all!

There seem to be questions about both CTR reporting and SAR reporting.

For CTR purposes, when cash is deposited into a join account, it is understood to be on behalf of all account owners. When cash is withdrawn, it is generally assumed to be on behalf only of the person conducting the withdrawal, unless the bank has knowledge otherwise. You'd only have this knowledge if you asked or if the customer stated it up front.

Regarding SAR reviews, if these two scenarios are common occurrences, you probably need to do whatever level of due diligence is necessary to profile the customer and understand the source and use of these funds, and use that to decide whether or not a SAR is warranted. I would think this due diligence would require asking the customers what they're doing.

I agree that the SAR component of these scenarios is dependent on what the customers appear to be doing. My first reaction when reading the two hypotheticals is that there is structuring going on, and I'd want one very good explanation to the contrary before I'd tuck them into a "No Report" file. Especially if the customers repeat the pattern.