If a customer withdraws $9,999 and later deposits $10,000 on the same day in the same account, is a CTR required?

If a customer withdraws $9,999 and later deposits $10,000 on the same day in the same account, is a CTR required?

• A. No, because transactions are in opposite directions and neither exceeds 10,000
• B. Yes, because deposits trigger CTR
• C. No, because CTR only applies to cash withdrawals
• D. Yes, because total sums exceed 10,000

Answer: (A)

A Currency Transaction Report is required when cash transactions reach over $10,000 in a single business day, and that threshold is typically evaluated for cash-in and cash-out activities. The important factor is whether the transactions are in the same direction and can be aggregated as related cash movements. In this scenario, one cash-out of 9,999 and a cash-in of 10,000 occur on the same day for the same customer. Neither transaction alone exceeds $10,000, and they are opposite in direction. Because they are not both cash-ins (or both cash-outs) and the amounts don’t exceed the threshold on their own, they aren’t aggregated to exceed $10,000 for CTR purposes. Therefore, no CTR is triggered. If there were multiple deposits totaling more than $10,000 in a day, or multiple withdrawals totaling more than $10,000 in a day, or a single cash transaction over $10,000, then a CTR would be required.

A Currency Transaction Report is required when cash transactions reach over $10,000 in a single business day, and that threshold is typically evaluated for cash-in and cash-out activities. The important factor is whether the transactions are in the same direction and can be aggregated as related cash movements.

In this scenario, one cash-out of 9,999 and a cash-in of 10,000 occur on the same day for the same customer. Neither transaction alone exceeds $10,000, and they are opposite in direction. Because they are not both cash-ins (or both cash-outs) and the amounts don’t exceed the threshold on their own, they aren’t aggregated to exceed $10,000 for CTR purposes. Therefore, no CTR is triggered.

If there were multiple deposits totaling more than $10,000 in a day, or multiple withdrawals totaling more than $10,000 in a day, or a single cash transaction over $10,000, then a CTR would be required.