An individual comes into the bank and makes a $6,000 cash deposit into a checking account. At the same time, the individual buys a $7,000 cashier’s check with cash. According to the Bank Secrecy Act, what is the bank is required to do?

The BSA requires the aggregation of multiple currency transactions conducted by or on behalf of the same person during a single business day. The individual conducted two cash-in transactions: a $6,000 deposit and a $7,000 cashier's check purchase, totaling $13,000. Since this aggregate amount exceeds $10,000, the bank must file a CTR for the total amount. The bank must also comply with the recordkeeping requirements for the purchase of the monetary instrument. Option D is the most complete and accurate description of the bank's obligations.

A. A large cash transaction alone is not inherently suspicious and does not automatically trigger a Suspicious Activity Report (SAR) filing.
B. This fails to aggregate the two transactions, which is a key requirement of the BSA for CTR filing purposes.
C. While aggregation and record retention are required, this option omits the mandatory CTR filing for the aggregated amount exceeding $10,000.

1. Federal Financial Institutions Examination Council (FFIEC). (2021). Bank Secrecy Act/Anti-Money Laundering Examination Manual. "Currency Transaction Reporting – Aggregation," Page 137. "Banks must aggregate multiple currency transactions...if the bank has knowledge that the transactions are by or on behalf of the same person and result in either cash in or cash out totaling more than $10,000 during any one business day."

2. U.S. Government Publishing Office. (2023). Code of Federal Regulations, Title 31, § 1010.313 - Aggregation. "Multiple currency transactions totaling more than $10,000 during any one business day are treated as a single transaction if the financial institution has knowledge that they are by or on behalf of any person."