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)

Currency Transaction Reports are required when a cash transaction exceeds $10,000 in a single business day. Each cash activity is evaluated against that threshold on its own.

In this scenario, the withdrawal is 9,999, which is below the threshold, and the deposit is exactly 10,000, which is not above the threshold either. Because neither cash transaction individually surpasses $10,000, no CTR is triggered. The fact that they occur on the same day and in opposite directions does not by itself create a CTR unless there’s a transaction that exceeds the limit or a pattern intended to evade reporting.

If a cash withdrawal or cash deposit had been over $10,000, or if there were related transactions that collectively exceed $10,000 with evasion intent, then a CTR would be required.