Questions and Answers
Do withdrawals of cash and deposits of cash need to be aggregated to determine whether a currency transaction report (CTR) should be filed?
No. The Bank Secrecy Act regulations require aggregation of multiple cash transactions by or on behalf of any person that result in either cash in or cash out totaling more than $10,000 during any one business day for CTR purposes. See 103.22(c)(2).
If total cash-in is over $10,00, that amount should be entered on item 26 of the CTR. If total cash-out exceeds $10,000, that amount should be listed on line 27 of the CTR.
Keep in mind that even though a CTR may not triggered, the background of the customer and the circumstances surrounding the transactions may require the filing of a suspicious activity report.
(Posted: 04/17/2008)
