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#1189255 - 05/22/09 04:01 PM EXEMPT CUSTOMER DILEMMA
lpramey67 Offline
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Joined: Aug 2006
Posts: 128
We have an exempt customer who took $11,000.00 in cash after negotiating a check that was drawn from their account at another institution. We are unsure how to address this transaction, including whether or not a CTR is required.

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#1189268 - 05/22/09 04:11 PM Re: EXEMPT CUSTOMER DILEMMA lpramey67
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You exempted the business.

If he conduted a personal transaction you would have to file a CTR.

He is not exempt.

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#1189307 - 05/22/09 04:43 PM Re: EXEMPT CUSTOMER DILEMMA MagicCity
lpramey67 Offline
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Joined: Aug 2006
Posts: 128
The check they negotiated was drawn from an account, at another institution, but the account was also a business account. Does that make a difference?

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#1189315 - 05/22/09 04:49 PM Re: EXEMPT CUSTOMER DILEMMA lpramey67
Al Miller Offline
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Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Who benefited from the transaction? Did the $ go into the till at the business or into the pocket of the owner?

Al
_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1189391 - 05/22/09 05:48 PM Re: EXEMPT CUSTOMER DILEMMA lpramey67
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
Next to Harvey
Assuming this is a phase II exempt person, the only transactions that are exempt are deposits and withdrawals in connection with the accounts you actually included in your exemption review.

If he cashed a check drawn on another bank it is a reportable transaction.

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#1189667 - 05/23/09 05:43 PM Re: EXEMPT CUSTOMER DILEMMA lpramey67
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Originally Posted By: lpramey67
The check they negotiated was drawn from an account, at another institution, but the account was also a business account. Does that make a difference?


No, it does not.
You exempted your business entity only.
As Ken says above, - the only transactions that are exempt are the deposits and withdrawals to/from that account.

If the owner of the exempted entity comes in with a check from another bank, then the transaction is reportable.

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