Skip to content
BOL Conferences
Thread Options
#2144022 - 08/29/17 04:25 PM CTR Question for cash in and out
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
If a customer brings in $18,000 in currency and deposits $12,000 into his account and takes the rest back in large bills, do I put the $18,000 as cash in and $6,000 as cash out?

Return to Top
BSA/AML/CIP/OFAC Forum
#2144025 - 08/29/17 04:31 PM Re: CTR Question for cash in and out Susielou
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
don't worry about the cash out as it did not aggregate to over $10,000
_________________________
CRCM, CAMS

Return to Top
#2144027 - 08/29/17 04:40 PM Re: CTR Question for cash in and out Susielou
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
So do I just report the actual cash that was deposited or the total amount that was presented?

Return to Top
#2144030 - 08/29/17 04:53 PM Re: CTR Question for cash in and out Susielou
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
you want to capture all of the cash that aggregates over $10,000, so I'd file the CTR like this:

25a - $12,000
25e - $6,000
_________________________
CRCM, CAMS

Return to Top
#2144038 - 08/29/17 05:16 PM Re: CTR Question for cash in and out Susielou
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
Thanks!

Return to Top
#2144241 - 08/30/17 03:44 PM Re: CTR Question for cash in and out Susielou
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 362
Midwest
What if the total cash brought in was $12,000. Deposited $4,000 and exchanged $8,000 for big bills. Would I still list it the same way you described?

Return to Top
#2144243 - 08/30/17 03:49 PM Re: CTR Question for cash in and out Susielou
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,951
Illinois
Aggregate cash in still exceeds $10,000 so

25a $4,000
25e $8,000
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2144312 - 08/30/17 06:00 PM Re: CTR Question for cash in and out Susielou
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
I agree with Brian
_________________________
CRCM, CAMS

Return to Top
#2144362 - 08/30/17 08:37 PM Re: CTR Question for cash in and out Susielou
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Go to the User Test System and input your example. The report will not total item 27 (cash outs) because the amount does not exceed $10K. It will total item 25 (cash ins) as $12K. The report can do the math.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2197760 - 11/08/18 03:56 PM Re: CTR Question for cash in and out Susielou
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Dusting off this old thread. If the customer brought in $20,000 and deposited $18,765.23 into a CD to bring it up to an even amount and took the rest back in cash, would that still be reported as 25a: $18,766 and 25e: $1,235?
_________________________
Go Packers

Return to Top
#2197768 - 11/08/18 04:15 PM Re: CTR Question for cash in and out Susielou
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
yes
_________________________
CRCM, CAMS

Return to Top
#2197802 - 11/08/18 06:38 PM Re: CTR Question for cash in and out Susielou
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
You would not report the cash back as it is below 10k
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2197812 - 11/08/18 06:57 PM Re: CTR Question for cash in and out RockChucker, CAMS
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
Originally Posted By RockChucker, CAMS
You would not report the cash back as it is below 10k


the 1235 was a currency exchange that would be required to be reported in field 25e
_________________________
CRCM, CAMS

Return to Top
#2197834 - 11/08/18 08:12 PM Re: CTR Question for cash in and out Susielou
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Ahh, I was thinking you were reporting the cash back to the customer.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2197916 - 11/09/18 03:15 PM Re: CTR Question for cash in and out Susielou
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 355
Wait what? The 1235 is a non-event. It wouldn't even show on any reporting. The customer threw 20k on the table and only deposited 18766 and put the 1235 back in his wallet. Why would you report that? That makes no sense.

Return to Top
#2197935 - 11/09/18 04:17 PM Re: CTR Question for cash in and out Susielou
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,313
it's a currency exchange
_________________________
CRCM, CAMS

Return to Top
#2197938 - 11/09/18 04:23 PM Re: CTR Question for cash in and out Susielou
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 388
I agree with praBSA, I wouldn't necessarily call that a cash exchange based on how Bec explained it.

If it's actually a cash exchange (Here's 20k in 20s, I want 18k in my CD and the rest back in large bills) then it should be reported. If it's just change, like praBSA said, I wouldn't report it.

Return to Top
#2197939 - 11/09/18 04:25 PM Re: CTR Question for cash in and out Susielou
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 355
^ That's how I read the scenario. If bills were exchanged, sure, but BEC explained the customer was handed their own money back.

Return to Top

Moderator:  Andy_Z