Do we need to file a CTR for nonmembers?

A nonmember walks into a credit union’s branch in location A and completes a wire transfer for $6,000 to John Smith. Later that day, the same nonmember visits a different branch – in location B – and requests another wire transfer to John Smith for $6,000. Both transactions involve cash. Neither branch is aware of the wire transfer made at the other location. Does this credit union need to file a currency transaction report (CTR)? Aggregating transactions for CTRs can be tricky, especially when nonmembers are involved.

Section 1010.311 of the FinCEN regulations requires financial institutions, including credit unions, to file a CTR for “each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to such financial institution which involves a transaction in currency of more than $10,000…”

Importantly, section 1010.313 requires a credit union to aggregate multiple currency transactions – and therefore treat them as one single transaction – if the credit union “has knowledge” the transactions:

  1.  occur in a single business day;

 

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