CTR for Multiple Employee Bonus Checks?

Answered by:

Question:

Two employees of a business came into the bank to cash their bonus checks. The transactions were treated as separate transactions. Both checks were drawn on the same business account and the total of both checks cashed was over $10,000. Should we file a CTR?

Answer:

If the transactions were for the benefit of the individual employees and the transactions were conducted separately, there was no one individual that benefited from, nor was there a single transactor involved in, a cash transaction over $10,000.

First published on BankersOnline.com 1/03/11