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#341044 - 03/30/05 10:52 PM CTR structure
Anonymous
Unregistered

We have an organization that recently deposited over $10,000 into an account. It is not a registered organization and does not have a taxpayer id. In this instance, would we put the organizations name and use the individual who opened the account's social security number? i am confused and do not know how to file this particular CTR.

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#341045 - 03/31/05 01:43 AM Re: CTR structure
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
How and why do you continue to bank an organization such as this? I think it present issues for the bank from a CIP and BSA perspective. There are few really correct answers to your questions. I would report whatever information is available.
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#341046 - 03/31/05 08:03 PM Re: CTR structure
complianceman Offline
Platinum Poster
complianceman
Joined: Mar 2005
Posts: 687
New Albany, IN
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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