Question:

I attended the league’s “Bank Secrecy Act (BSA) for BSA Staff” Compliance Essentials training on August 21st. You spoke about when to check Item 3, “multiple transactions” on a Currency Transaction Report. Can you also explain when we check the Item 24 option “aggregated transactions” on the CTR and how these two items differ?

Answer:

Of course!

The CTR Item 3 “Multiple transactions” is related to, but not the same as, the Item 24 option, “Aggregated transactions.

• Item 3 should be checked each time multiple transactions are reported as a single transaction.
• The Item 24 option “Aggregated transaction” should only be checked when all the specific conditions underlying that option have been satisfied.

When to Mark the “Multiple Transactions Box

Item 3 “Multiple transactions” should be checked if a person or entity conducts more than one cash-in or cash-out transaction in a single business day, regardless of transaction amounts.

Examples:

• If Tom deposits $6,000 in the morning and $5,000 later the same day, Item 3 is checked for Tom.
• If Tom deposits $7,000 into a business account and Jane later deposits $5,000 into the same account on the same day, Item 3 is checked for the business account (the entity), but not for Tom or Jane individually.

When to Mark the “Aggregated Transactions” Box
Filers should check box 24e “Aggregated transactions” (along with any other applicable box in Item 24) only when all three of the following conditions are met:

1. The financial institution did not identify any of the individuals conducting the related transactions.
2. All of the transactions were below the $10,000 reporting threshold.
3. At least one of the aggregated transactions was a teller transaction.

What is a “Teller Transaction”?
A teller transaction includes, but is not limited to, the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window, or an individual exchanging currency at the teller window.

Teller transactions are distinguished from non-teller transactions (e.g., ATM deposits, mailed deposits, armored car pickups) because they involve direct face-to-face interaction with institution staff.

Examples:

• If there were four $3,000 deposits made into ABC Restaurant’s business account in one business day, and the filing institution did not identify any of the individual transactors, and at least one of these deposits was made via a teller transaction, the institution would complete a Part I on ABC Restaurant, checking Item 3 “Multiple transactions” and checking “Aggregated transactions” in Item 24.
• However, if the institution identified the fourth individual transactor, knowing that the additional deposit pushed the account over the $10,000 threshold, then the institution would complete a Part I on ABC Restaurant (checking Item 3 “Multiple transactions”) and a separate Part I on the identified transactor. In this case, the institution would not check “Aggregated transactions” in Item 24 because one of the individuals was identified.
• If there were four $3,000 deposits made into ABC Restaurant’s account via any combination of armored car (FI contract), ATM, mailed deposit or shipment, or night deposit, and none of the deposits were teller transactions, the “Aggregated transactions” box should not be checked. Instead, the institution should check the other Item 24 boxes (such as “Night Deposit” or “Armored Car”) as applicable.