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Cash Deposit At Teller Counter-CTR?

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Question: 
A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.
Answer: 

Even if you accept that the whole thing was a mistake, more than $10,000 crossed the counter and came under the teller's control. Treat it as a cash deposit of $10,000 and a currency exchange of $100.

I can't respond to the idea of considering a SAR without knowing what transpired during the transaction. That has to be your call.

First published on 01/13/2019

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