We have a client who operates a check cashing store. Every week they come in and take out about $250,000 in cash, which they need on hand for check cashing. We have been completing CTRs as needed.

For security reasons, we suggested to the client that they get their own account with IBB and order directly so the cash can be delivered there. Now that we are doing that, do we still need to complete a CTR? IBB says they do not complete CTRs and that it is still our responsibility. However, cash is not leaving the bank any longer, it is going from IBB to the client directly. What is the proper way to handle this transaction?

If IBB is an amored car service and they are providing the cash directly from there vault processing the transaction then they should be doing the CTR. If IBB is just delivering from the bank vault and the bank is taking the order and doing the transaction then the bank(you)should be doing the CTR.

I would say it can be a bit more complicated.

If IBB is an agent for the bank, then the bank has the obligation, even if the cash comes from the cash vault of IBB.

I would check to see what relationship IBB and the bank have.

I'm not familiar with what or who IBB is, but they are most likely correct that it would still be the bank's responsibility.

You might want to review this thread. and also follow the link to the other post I referred to for the Administrative Ruling regarding this process.