Example in question: Mr & Mrs Customer requested a transfer of $20,500.00 (from their joint account with our institution) to their daughter's account (single ownership account with same institution). For privacy purposes, we ran the transaction as a cash withdrawal from the parent's account and as a cash deposit to the daughter's account. Because it was a transfer request, we are unsure as to whether or not we should consider this for CTR reporting, SAR reporting, or log it in our over $3000.00 log as a transfer of funds between two Social Security numbers. Any help or input about this would be greatly appreciated!! Thank you-

If you didn't physically receive or give out the money to anyone you don't have a CTR to file.

Is the transactions suspicious? What about it makes you feel something is suspicious?

I'm not sure why you would need to put this transaction in your $3000 log either. It seems to be a simple transfer of funds between two accounts.

I agree- there's nothing to report, because the transaction did not involve actual currency.

Sooo.... How much CASH actually was withdrawn and/or deposited that you want to log, file, report?

What is the felonious act they are suspected of committing?

I don't think the transaction was concocted; nor do I believe the question came out of a desire to do something to the customer. The bank simply used fictitious cash transactions to facilitate the transaction requested by the customer. Now the bank is wondering whether it needs to treat it as a cash transaction. Had the bank handled this in another way, the question would never have come up.

I don't think the question involved WANTING to report the transaction. The question is WHETHER, and we've answered it with a resounding "NO."

It is a transfer of funds subject to the recordkeeping rules for transfers of $3,000 and up. The "cash" was simply a contrivance on the part of the bank to facilitate the transfer.

I'm not understanding why "privacy" came into this. Did the parents not want the daughter to know they transfered the $20,500? What privacy issues are there? If you completed a transaction authorized by the customer, there are no privacy issues, and you made a simple transaction much more complex.

You will probably need to write some sort of memo to some sort of file to explain why this virtual "cash" transaction is not being reported on a CTR in case the question comes up in an audit or an exam.

Beyond that, I think you need to examine why you believe you needed to conduct the transaction in the manner in which you did.

While there was never any acutal cash...I can see it now...a BSA examnier or IA coming and it appearing as if this was a cash transaction...the transaction better be well documented that no cash actually left or came into the bank. From my POV (as internal audit), I see cash tickets I want to know where the CTR is?