Completing a CTR involving multiple transactions

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Question:

We have a situation where a customer deposited $10,000 cash into their account that is owned by two other individuals. Later in the same day, one of the individuals makes a $200 change order on their own personal joint account. How do we complete the CTR? Do we include the 3 joint account owners for the $10,000 cash deposit, then add a role for the individual for the $200change order or do we only list the individual that was involved with the $10,000 cash deposit, with the transaction being conducted on their behalf (with no one conducting the transaction) and the $200 change order conducted on their own behalf.

Answer:

First, let's review two basic CTR "rules":

(1) A CTR is required when one or more "cash-in" or "cash-out" currency transactions exceeding $10,000 on the same business day are conducted BY a person or ON BEHALF OF a person that is not exempt.

(2) When the "cash-in" or "cash-out" transactions exceed $10,000, all known persons who conducted, and all persons on whose behalf they were conducted, are identified in the CTR.

Now, let's name the three individuals involved Andy, Bob, and Chuck.

If Andy conducts both the $10,000 deposit and the $200 currency exchange (the change order), the answer is easy. There will be a CTR Part I identifying Andy as the conductor on his own behalf (item 2a checked), with $10,200 and the joint account number in item 21. There will also be a Part I for Bob and another for Chuck, each with item 2c checked, and $10,000 and the joint account number in item 21. Item 3 will be checked on Andy's Part I because more than one transaction is included.

But If Andy conducts the $10,000 deposit and Bob conducts the currency exchange, will there need to be a CTR? Yes, because both transactions, totaling $10,200, were conducted on Bob's behalf, thus triggering the CTR requirement. In this case, there will be a Part I for Andy as conductor of the $10,000 deposit, with 2a checked, a Part I for Bob as conductor of the $200 currency exchange with 2a checked, a Part I for Bob with 2c checked for the $10,000 deposit, and a Part I for Chuck with 2c checked for the $10,000 deposit. Item 3 will be checked on Bob's Part I sections.