If two different people deposit $5,000 and $6,000 into the same business account on the same day, does this trigger a CTR?

• A. No, because two people are involved
• B. Yes, because combined deposits exceed $10,000 on the same account
• C. No, because it is a business account
• D. Yes, because both deposits were made to the same account

Answer: (B)

CTR reporting focuses on cash transactions where a single customer brings in more than $10,000 in a single day. The bank must file a CTR for cash deposits that, in aggregate for that customer, exceed the threshold, or for a single cash transaction over the limit. In this scenario, two different people deposit $5,000 and $6,000 on the same day into the same business account. Since each deposit is from a different customer and each amount is under $10,000, there is no single customer who has deposited more than $10,000 in that day, and no single transaction over the limit. Therefore, no CTR is triggered. If the same customer had made both deposits, or if there were a single deposit over $10,000, a CTR would be required. And if someone tried to split deposits to evade reporting, that would raise SAR concerns. But as stated, the understanding is that CTR is about a single customer's activity, not the total in the account from multiple customers.