Can anyone point to a clear definition or an agreed upon application of the term "has knowledge" related to CTR filing purposes?

One situation we have is that a Teller may post a cash deposit to a business account for $5,000 early in the morning. Later the same day, the same teller may post an additional cash deposit for the same conductor for $8,000 to an account not related to the first account (for example the conductor is a treasurer for a church and also owns a restaurant). Has it been defined anywhere that the same teller processing the transactions would constitute "having knowledge?"

It's hard to hold a person accountable for remembering and to consistently enforce this standard.

Any reference to actual guidance that you know of would be greatly appreciated.

That is why most banks document conductor information on amounts less than $10,000 - that way there is no question and you don't leave it up to a poor teller to remember every transaction. In this instance, the teller should have knowledge unless they are a really busy teller. How many tellers do you know that actually do not recognize a customer that has been in earlier in the day?

Even if you do not use a software to aggregate, I would think you would have a report that would. We do not use our canned system reports anymore, but it would have caught this as long if the conductor was associated with both accounts. Where an old school report would miss completely is if the conductor was not associated with an account.

In this example the conductor only has role on one account. We have aggressive aggregation settings on our software but it can only aggregate what there is two data points for.

My bank already has around 35,000 reportable transactions each year. Management has no appetite to lower the threshold. Lacking a specific definition of has knowledge, it would really take an exam finding to move in the direction of gathering conductor information at lower levels. What that finding would be based on is unclear to me or how the missed CTRs would be identified is unclear. I would like to resolve the issue before it ever got to that point, but I can't make factual argument.

In the situation where you gather conductor information at all levels, are you then going back and aggregating that information daily looking for common conductors? For us that would be a few thousand transactions each day, plus deciphering and aggregating ATM conductors.

It seems like CTRs can potentially have an near infinite level of depth and the line just has to be drawn somewhere.

I think some tellers would remember and some wouldn't. If I was a teller, I don't think I would remember every person that comes in. I have to check my calendar sometimes to remember who I had an hour long meeting with sometimes

I would like to know how you pull in ATM conductors.

ATM withdrawals are made with a card and a pin assigned to one person. That person is the conductor.

How do you track the ATM information? Does your system track this?

I agree with rlcarey, it seems implausible a teller would not recall a person who brought that sum of cash in the morning as they are processing an equally large sum of cash in the afternoon. Choosing not to document conductor information for transactions under $10,000 while simultaneously not being able to rely on those that process the transactions under the threshold to alert proper channels makes it appear as if you have a large hole in your reporting process. Sure, you can't catch every aggregated scenario no matter what system you employ. But, you can't have your cake and eat it too either.

The ATM card used is associated with the transaction in the core system. There is another part of the core system that tracks who the cards are assigned to. Reports from both systems are merged giving the conductor based upon which card was used.