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#364336 - 05/26/05 06:15 PM large currency deposits using foreign ATM
Anonymous
Unregistered

If someone uses our ATM to make a deposit to their account at another financial institution, and it exceeds $10,000 in cash, how do we obtain information to complete a CTR? With Financial Privacy Act, can the depository bank give us this information?

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BSA/AML/CIP/OFAC Forum
#364337 - 05/26/05 06:23 PM Re: large currency deposits using foreign ATM
Sound Tactic Offline
Power Poster
Sound Tactic
Joined: Feb 2005
Posts: 5,349
Someone put $10,000 cash into an ATM? Wow.
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#364338 - 05/26/05 06:37 PM Re: large currency deposits using foreign ATM
WildTurkey Offline
Platinum Poster
WildTurkey
Joined: Jan 2003
Posts: 921
Down South, USA
You might try arguing that the USA PATRIOT Act, s314(a) covers the information that you need for your CTR.
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This is my opinion; it is not legal advice, nor the view of my employer, and it may change tomorrow.

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#364339 - 05/26/05 06:53 PM Re: large currency deposits using foreign ATM
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Section B has box C that is to be checked in this situation, since you cannot identify the conductor.

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#364340 - 05/26/05 07:56 PM Re: large currency deposits using foreign ATM
Anonymous
Unregistered

Regarding the amazing fact that someone would put $10,000 cash into an ATM, yes, this is a business that takes in lots of cash and they don't want to keep it overnight or drive all the way to their Bank.

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#364341 - 05/26/05 08:00 PM Re: large currency deposits using foreign ATM
Anonymous
Unregistered

Quote:

Section B has box C that is to be checked in this situation, since you cannot identify the conductor.


We would not have any of the information for Section A unless the depository bank provided it to us, which brought up my concern about privacy.

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#364342 - 05/26/05 09:06 PM Re: large currency deposits using foreign ATM
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Section A is for the person who benefitted from the deposit (your customer).

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#364343 - 05/27/05 12:21 PM Re: large currency deposits using foreign ATM
Anonymous
Unregistered

Quote:

Someone put $10,000 cash into an ATM? Wow.


Will $10,000 in $100 bills actually fit in the deposit slot of an ATM? One of our fraud guys told me they'd figured out the maximum amount of cash that would fit in one deposit, but I cannot recall the number off the top of my head.

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#364344 - 05/27/05 12:58 PM Re: large currency deposits using foreign ATM
WildTurkey Offline
Platinum Poster
WildTurkey
Joined: Jan 2003
Posts: 921
Down South, USA
Quote:

.....Will $10,000 in $100 bills actually fit in the deposit slot of an ATM? ....


Multiple deposits by the same person and/or for the credit of the same account would be aggregated when considering if the $10,000 daily reporting limit had been breached.
_________________________
This is my opinion; it is not legal advice, nor the view of my employer, and it may change tomorrow.

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#364345 - 05/27/05 01:23 PM Re: large currency deposits using foreign ATM
Anonymous
Unregistered

Oh, I know that. It's just more fun to try to picture it as a single deposit. In high drug traffic areas we've seen dealers pay 8 or 9 year-old kids to make the cash deposits, they're too short to get a good picture on the ATM camera...

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