Banker's Compliance Consulting Blog

Banking Regulations Compliance | Multiple vs. Aggregated Transactions

Written by David Dickinson | Aug 8, 2017 4:00:23 AM

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.

Published
2017/08/08
Deb Irving