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Big Deposits: CTR or SAR?

Answered by: 
Kathleen Blanchard

Question: 
A customer deposited cash: $6000 one day and $5000 the following day to the same account. Should a CTR be filed since we noticed this trend or should the transactions be ignored since they occurred over a two day period? If we don't file the CTR, are we required to file a SAR?
Answer: 

The CTR would be filed if the transactions occurred in the same banking day; if they occurred on two separate banking days, no CTR would be filed. The SAR would be filed if, after looking into the purpose of the transactions, etc., the bank determined they were suspicious (possible structuring, etc.)

The CTR and SAR work independently of each other. Filing of one does not preclude filing of the other.

First published on BankersOnline.com 9/06/10

First published on 09/06/2010

Filed under: 
Security
Filed under security as: 
SAR

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