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I frequently (every week or so) go to an ATM that is in a bank that I do not have an account in. I withdraw $500 and the machine dispenses $20 bills. I then walk up to the teller and exchange the bills for smaller denominations. Today I was asked for my ID and that they needed it for potentially filing a currency transaction report. Ignoring the fact that $500 is way less than the $10,000 reporting requirements1, would this type of transaction ever require a CTR? The guidance makes it clear that changing currencies (e.g., Euros to USD) is a transaction that needs to be reported. Is asking a bank to exchange USD bills in one denomination to USD bills in a different denomination considered a transaction?

1 Potentially they were worried that I might be conducting lots of small transactions, although I would think that if I keep circling through the line they would eventually ask me to stop since I am not an account holder at their bank.

  • It wouldn't require a CTR.... which is why none were filed before. Why would anyone need $500 in bills smaller than $20s though ??? – xyious Aug 14 at 16:31
  • @xyious it is for petty cash expenditures, specifically a reoccurring $17 expense. – StrongBad Aug 14 at 17:46
  • The teller may have been referring to a Suspicious Activity Report (SAR); see fincen.gov/sites/default/files/shared/…. – Jack Fleeting Aug 14 at 20:23

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