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Question & Answer
Question: You said something in one of your answers about getting information from the customer to file a CTR. It was my understanding we were not to tell the customer we were filing on them.
Answer: There is nothing prohibiting you from informing the customer that you are filing a Currency
Transaction Report. Indeed, in some cases you need to get additional information from them to do so. There is also no obligation or need to tell them that you are filing. You may file after the customer has left, and do not need to notify them if you have complete information.
The Suspicious Activity Report (SAR) is another matter altogether. You must not tell the customer that it is being filed. There is a non-disclosure section of the legislation that prohibits you completely from informing the customer of the filing of an SAR. Make sure your front line people know this!
Copyright © 1996 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 6, No. 10, 8/96
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