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Joint Owners Make Withdrawals Separately-CTR?

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Question: 
If joint owners of an account make two separate withdrawals at different times of the day from the account which now totals over $10,000.00, is CTR required? Each individual withdrawal was less than $10,000.00.
Answer: 

If you have knowledge the joint owners benefit from the withdrawals, you should combine the withdrawals. For instance, if customer A says "We are headed to Vegas, so I'm getting this cash" then you should combine the withdrawals. If you don't have knowledge the joint owners both benefit from the withdrawals, you shouldn't combine them for CTR filing. However, you should review this for SAR reporting purposes.

First published on 07/01/2018

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