All of the banks I have worked for have had "someone else who does the work", because the BSA Officer had to be of significant authority, and frankly, very few people in that position want to file CTRs personally. I am the BSA Officer, among other responsibilities, at my current bank and do mostly oversight. I am also in charge of Compliance and an executive officer of the company and the holding company. Someone in our Deposit Services Dept. files the CTRs and the Security Officer files the SARs.