Occasionally, the compliance team receives questions about interesting transactions conducted by members and whether a Currency Transaction Report (CTR) is required. Credit unions take their BSA/AML requirements seriously and are sometimes tempted to file a CTR for a transaction that “feels off” but does not actually trigger reporting obligations. Let’s take a look at some examples of transactions that do not trigger the CTR requirements, although they may leave us feeling a little uneasy.
Example 1: Natalie Non-member comes into ABC Credit Union with an on us check for $13,150.00. She uses the check to purchase four cashier’s checks in the amounts of $1,000.00, $1,900.00, $4,500.00 and $750.00. She takes the balance in cash.
Explanation: No CTR is filed. In this example, the teller did not give the non-member more than $10,000 in cash, nor did the teller accept more than $10,000 in cash from the non-member. Had Natalie cashed the on-us check, the CTR threshold would have been met and a report would be required. However, because she used the funds to buy cashier’s checks and took the remainder (which was not more than $10,000) in cash, she did not trigger the reporting requirements.
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