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Including ATM withdrawals in CTRs

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The independent auditor who completed our BSA compliance review suggested that our bank should find a way to include customer ATM withdrawals when aggregating cash-out transactions for CTR purposes. Most of our customer ATM activity is at other banks' machines, because we only have two ATMs ourselves. Should be include withdrawals made at those other banks' machines, even though we didn't pay out the cash ourselves?

Yes, review the discussion of Aggregation of Currency Transactions on page 77 of the FFIEC BSA/AML Exam Manual (2007 edition). Your bank authorizes cash withdrawals by your customers when made at non-proprietary ATMs. The ATM-deploying bank acts as your bank's agent in making the cash payments. Since you know that the withdrawals are made in cash, you should, when you are aware of them, aggregate them with other cash-out transactions of your customer to determine whether to file a CTR, and, if a CTR is filed, include the ATM withdrawals among the transactions in the report.

[Editor's note: The section on Aggregation of Currency Transactions cited above is found on page 86 of the 2010 edition of the BSA/AML Exam Manual.]

First published on 4/26/10

First published on 04/26/2010

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