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#350603 - 04/23/05 12:36 AM DEA Agents Refusing CTR Conductor Info
Anonymous
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The BSA CTR instructions require banks to obtain Name, Address, and social security number for conductors of currency transactions. We have DEA agents bringing in seized currency for exchange to a cashiers check payable to the US Marshall. The agents are refusing to provide their personal information as the conductor because it compromises their undercover identity. The DEA Group Supervisor called this compliance officer asking that we stop asking for the personal conductor information and accept the DEA's EIN and local office address in place of the social and address of the conductor. He said the BSA is okay with this.

I explained that the BSA doesn't make exceptions for DEA agents who conduct currency transactions. Any suggestions?

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#350604 - 04/23/05 02:42 PM Re: DEA Agents Refusing CTR Conductor Info
rlcarey Online
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rlcarey
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Galveston, TX
Maybe someone else will have better luck locating it, but there use to be an Administrative Ruling or similar issuance that addressed this issue and provided for the protection of the identify of the undercover officer.
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#350605 - 04/23/05 03:56 PM Re: DEA Agents Refusing CTR Conductor Info
Sisyphus Offline
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Connecticut
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#350606 - 04/25/05 12:44 PM Re: DEA Agents Refusing CTR Conductor Info
HappyGilmore Offline
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Pulling people out of the ditc...
Wouldn't a simple solution to have a non-undercover DEA agent (possibly an administrative person) come and convert the funds?
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#350607 - 04/25/05 01:39 PM Re: DEA Agents Refusing CTR Conductor Info
John Burnett Offline
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John Burnett
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Cape Cod
As said above via MAJ's link to the FinCEN Q&A, the simple solution is to file a DEP on the investigating government agency. Do it once and you don't have to do it again.

Transferring custody of funds from one DEA agent to another for the sole purpose of making the filing of a CTR less cumbersome isn't what I want my tax dollars being used for.
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#350608 - 04/25/05 03:58 PM Re: DEA Agents Refusing CTR Conductor Info
Anonymous
Unregistered

I might be reading more into the original post than is there, but, I think that there will still be static as the OP follows the guidance in the Q&A.

Yes, they can file DEP on the agency, and that means the undercover officer's information won't go on the CTR.
No, the undercover officer isn't completely off the hook, since the last part of guidance suggests that the bank record enough identifying information about the officer to ensure that they're actual LEOs. The undercover agent is still likely to become cranky that the bank is collecting identifying info...

Just my US$.02 (which is worth less and less against leading currencies all the time....)

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