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#1202169 - 06/16/09 09:36 PM Is CTR req'd? Please help!
AKA nan Offline
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Joined: Mar 2008
Posts: 156
California
A man and woman walk into the bank together and go up to the teller window together. They each have accounts at the bank, but not jointly. They do, however, sign on the same SDB. They each cash a cashiers check made out to themselves as individuals, one for $6K (hers)and one for $7K(his). The cashiers checks, which are issued from another bank, are in sequencial order, as if they had them issued at the same time.

Is there any reason to complete a CTR? We know they live at the same address and that they were obviously at the other bank together, but I can't make myself believe that they were both benefitting from the transactions just because they completed the whole thing "together". The teller cashed the checks separately and gave each person his/her money separately.

Why is this hurting my head? This just happened so any input would be appreciated.
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#1202170 - 06/16/09 09:40 PM Re: Is CTR req'd? Please help! AKA nan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If you have no reason to believe that both benefited from both transactions, lay your head down and don't worry about this one.
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#1202179 - 06/16/09 09:51 PM Re: Is CTR req'd? Please help! rlcarey
AKA nan Offline
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Joined: Mar 2008
Posts: 156
California
I guess I just wish that the teller had done a bit of due diligence. I am in the middle of this argument between the BSA specialist and the teller and I can see both sides of the coin. However, I can't be sure they both benefitted (even though since they live together, my assumption is that they both would).
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#1202185 - 06/16/09 09:58 PM Re: Is CTR req'd? Please help! AKA nan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If you think that I benefit from the cash withdrawn at the bank by my wife, I think you need to get out into the real world more often smile

There is not enough evidence to suggest a CTR is required. If you think they structured the transactions, then file a SAR.
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#1202194 - 06/16/09 10:15 PM Re: Is CTR req'd? Please help! rlcarey
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Yes it sounds more like a SAR is necessary - rather than a CTR.

document document document
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#1202502 - 06/17/09 03:35 PM Re: Is CTR req'd? Please help! WonderWoman
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
I agree with (not as) that this certainly looks like a SAR candidate and not a CTR candidate.

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#1202514 - 06/17/09 03:43 PM Re: Is CTR req'd? Please help! devsfan
YoungAndEager Offline
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Joined: Apr 2009
Posts: 135
Indiana
Who was the remitter on each of the cashier's checks? Was it

From John Doe to John Doe
From Jane Doe to Jane Doe

The only reason I ask is if they had a joint account at the issuing bank, then they would be avoiding CTR
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