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Report $300 Currency Exchange on CTR?

Here is the situation: a customer deposits $12,000 in cash; they also do a currency exchange for $300 (cash in and cash out). Our processor states that the $300 out does not need to be reported on a CTR since it is not over $10,000. Is this correct?

Answer by Randy Carey: Your processor is wrong. The total cash in would be $12,300.


Answer by John Burnett: When the bank has knowledge that multiple currency transactions have been conducted on behalf of the same person on a given business day, the bank is required to aggregate them in a single CTR. If the deposit and currency exchange you describe occurred on the same business day, combine the two cash-in amounts for a total of $12,300 to be reported. The cash-out portion of the currency exchange is not reported because aggregate cash-out transactions on behalf of the customer are below the reporting threshold.

And don't ever forget that your bank, not its processor, will bear the onus of not filing correctly.


Answer by Ken Golliher: As noted, yes it has to be included in the "cash-ins" and no, it is not listed in the "cash-outs." If you want proof for your vendor fill out the demonstration version of the CTR. It will readily add the $12,000 and the $300 cash-ins, but will not let you file the form showing only $300 in cash-out's.

First published on 5/13/13

First published on 05/13/2013

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