We are often asked what the difference is between “multiple” and “aggregated” transactions when completing the Currency Transaction Report (CTR). The “multiple” transactions box is marked whenever there are multiple cash-in or cash-out transactions of any amount conducted in a single business day by, or for, a person. “Aggregated” transactions, on the other hand, involve multiple transactions ALL of which are 1) below the reporting requirements ($10,000); AND, 2) where at least one of the transactions was a teller transaction; AND, 3) the bank did not identify any of the individuals conducting the related transactions. If you have “aggregated” transactions, you will also always have “multiple” transactions. However, the reverse is not always true – you could have “multiple” transactions without marking the “aggregated” transactions box because, for example, one of the transactions may have been over $10,000; or perhaps none of the transactions were teller transactions; or maybe identifying information was obtained on one of the conductors.
Do you have other areas that puzzle you when it comes to completing the CTR, exempting customers, or what information and when to collect it on monetary instrument purchases? If so, join us for our “CTRs, Exemptions and Monetary Instruments” webinar.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!