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CTR for Split Deposit w/Foreign Personal Check?

Question: 
Do we have to file a CTR on the following transaction? A split deposit: customer brought a foreign personal check $16,000 which the teller converted into cash, deposited $14,000.00 - the actual amount cashed out by customer is $2,000, but teller run this $14k as cash deposit for convenience.
Answer: 

No, it is not reportable; while the teller created a 14K cash-in, there was no 14K in cash. However, your software will likely show a false positive that any third party reviewer should question. Write your explanation in advance.

Your processes should be strict enough that tellers do not think they have this much discretion...

First published on BankersOnline.com 2/20/12

First published on 02/20/2012

Filed under: 
Compliance
Filed under compliance as: 
IT
Tellers

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