Question & Answer

Question: If a customer comes in to the bank with $10,500 in cash and purchases official checks, one for $5,000 and one for $5,500, what BSA reports - CTR and monetary instrument log - should be filled out?

Answer: The monetary instrument log is designed to complement the CTR - for example, to pick up transactions that are not otherwise reported. Because these two checks were purchased contemporaneously, you aggregate the amount of the checks purchased and that amount exceeds $10,000. Thus, this transaction is fully reported on the CTR. If, however, the customer had brought in the same amount of cash but purchased only one check for an amount between $3,000 and $10,000, that check would be recorded on the Log and a CTR would be filled out for the cash-in transaction.

Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 12 & 13, 10/97