How was the account opened? Individual or a business entity? If it is a business entity, ask them what the Tax ID number is and get it in your system. Then file the CTR. If they do not wish to provide a Tax ID for the business entity, file the CTR and a SAR. That should fix the problem in the interim. Then force the business entity to get a Tax ID or close the account. Lost business is better then the applicable risk!!!
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The opinion stated here is what it is, My Opinion.