Question:
Would a CTR be required if several individual employees endorsed their respective payroll checks (all individual payroll checks are under $10,000 but combined they aggregate to an amount that exceeds $10,000), and the owner of the business (which is exempt phase 2) cashed them for the purpose of distributing the proceeds back to the individual employees?
Is this allowed under an exemption?
PS - Our Compliance BSA Officer abruptly left the bank with no guidance, and we are trying to make sure we do things correctly.