Compliance Alliance Q&A 2/19/2020

Question:
Regarding CTRs, when there is an aggregated transaction, what are the requirements in order for the transaction to be considered an aggregated transaction?

 

Answer:
The bank would report as an aggregated transaction only if, 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) of all the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. All three requirements must be met. 

27. When do you check the “Aggregated transactions” box (Item 24)? 
Filers should check box 24e “Aggregated transactions” (along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check “Aggregated transactions” as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 “Night Deposit.” A “teller transaction” would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. The option “Aggregated transactions” is not the same as Item 3 “Multiple transactions,” which can involve transactions that are above the reporting requirement.

Frequently Asked Questions Regarding the FinCen Currency Transaction Report (CTR) #27: https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr

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