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 aggregated transactions 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 aggregated 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.
Be sure to refer to the FinCEN FAQs for a more detailed explanation and scenarios related to multiple (Question 18) and aggregated (Question 27) transactions.