By Heather Campbell, CIA
While we are told to “aggregate” transactions on a Currency Transaction Report (CTR), that does not mean we are to mark the aggregated transactions box. The “multiple transactions” box (Part I Box 3) is marked any time there are multiple cash-in or cash-out transactions of any amount conducted in a single business day by, or for, the person/entity identified in Part I. There are three specific requirements of marking aggregated transactions on a CTR.
The box (Part II Box 24) should only be marked if ALL three of the following conditions are met:
- The bank did not identify any of the individuals conducting the related transactions.
- ALL the individual transactions making up the total were less than the reporting requirement ($10,000).
- At least ONE of the transactions went through a teller window, i.e. an individual brought the transaction to a teller and was not identified at the time of the transaction. All of the aggregated transactions cannot have been conducted through the night deposit, mail, ATM, or armored car.