I have a situation regarding the aggregation of cash transactions being conducted after cut off on Friday and over the weekends. In all cases I've ever seen, a bank will aggregate these transactions on Monday's business date to determine if a CTR should be filed. However, I've run into a situation where that's not the case.

This particular bank has the staff levels to look back and determine if transactions are being conducted on a Saturday and Sunday and aggregate them based on those dates (I know what you're thinking, "You're a liar and a thief ACB, no bank has that level of AML staffing." But no, miracles do happen). My issue is that there AML software flags the transactions posted on Monday and triggers a CTR which is subsequently not filed. Additional questioning confirmed that all transactions conducted over the weekend post on Monday's business date.

I checked the manual and observed the comment about multiple currency transactions totaling more than $10,000 during any one business day being treated as a single transaction. I’ve additionally called the helpline for final guidance. However, there is some debate about what constitutes a “business day.” For example, if the bank is open Saturday and Sunday, those are business days and they are free to aggregate based on those days alone. My concern that there systems actually post all transactions on Monday. It would seem, at least to me, that the definition of a business day shouldn’t supersede their actual processes?

I’ve never seen a bank operate this way. Is anyone handling weekend transactions in this manner? If so, has it been an issue during examinations? More importantly, I still think this is being done incorrectly. Does anyone disagree on this? If so, why?

i) Business day. As used in this chapter with respect to banks, business day means that day, as normally communicated to its depository customers, on which a bank routinely posts a particular transaction to its customer’s account.

Sorry, but all I can offer you is complete agreement. If my three $6,000 deposits are made on Friday, Saturday, and then Monday, but they all carry the same posting date on my statement, they are subject to aggregation. No debate. No discussion.

Per the definition above, that's the way it's always been. They are undermining their own software.

I was hoping you would disagree with me Ken. But it is what it is. Could I inquire as to where you obtained that definition?

not exact wording but

http://www.federalreserve.gov/boarddocs/SupManual/bsa/bsa_p2.pdf

search for business day

We too look at each days deposit (branch personel)but only to ensure all are properly agged.

ACBbank: The definition is in fincen's regulations: http://www.bankersonline.com/regs/31-1000/31-1010-100.html

31 CFR Part 1010, Section 1010.100(i)

See http://www.bankersonline.com/regs/31-1000/31-1010-100.html

Thanks everyone. As always, I'm in your debt.

Just an FYI - we're an online bank, and transactions conducted on Saturday do post to our customers' accounts on Saturday. For CTR purposes, Saturday is considered a separate business day.

What date shows on the customer's statement for that Saturday deposit?

What date shows on the customer's statement for that Saturday deposit?[/quote]

Hi, John. Saturday deposits reflect Saturday's date on the customer's statement.

OK. Thanks. In that case, you would have to consider Saturday a business day for CTR aggregation purposes, and Saturday business would not be combined with Monday's.

Now you need to look back and see if you missed any CTRs.

No need - we've considered Saturday a separate business day for CTR purposes for at least the past 7 years.

Sorry Cape Codder, I was referring to the original poster. I agree your bank has a different situation. If I'm reading the original post correctly, they may have an issue with missed CTRs.