Q: A business customer of a depository institution provides payroll checks to individual employees for work performed. Each payroll check is under $10,000. However, several employees cash their payroll checks individually on the same business day, which results in an aggregate cash out from the business customer’s account in an amount exceeding $10,000. Would the institution be required to file a CTR, if no one person received an amount in excess of $10,000?
A: The financial institution would not need to file a CTR because it would not be involved in a single cash transaction (or multiple cash transactions for which a duty to aggregate would arise) of more than $10,000. A financial institution must treat multiple transactions in currency as a single transaction if the financial institution has knowledge that the multiple transactions are "by or on behalf of any person" and result in cash in or cash out totaling more than $10,000 during any one business day. According to the facts described above, the cashing of checks would be conducted by or on behalf of each individual employee (rather than the business on whose account each check is drawn), and no one employee would be cashing more than $10,000 in a single transaction or in multiple transactions during the same business day.
This FAQ was obtained from FinCEN’s website, in the section for Answers to Frequently Asked BSA Questions, which may be found here: