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#415686 - 08/29/05 10:24 PM CTR Question - Beneficiary?
Mel Offline
100 Club
Joined: Mar 2004
Posts: 100
Another financial institution (Bank A) next to our branch was short on 20's, so they came to us (Bank B) to "buy" currency. An employee from Bank A walked over with a cashier's check that was payable to Bank B. The item was negotiated and over $10,000 in cash was disbursed to Bank A's employee. Because Bank B has knowledge that Bank A will benefit from this transaction, is Bank A the beneficiary and the employee who walked out with the cash the conductor? Thanks.

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#415687 - 08/30/05 01:11 PM Re: CTR Question - Beneficiary?
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
That would be the way you should file the CTR, if you file it. However, filing CTRs on transactions between banks is a waste of time, energy and effort. Before 30 days from the date of the transaction goes by, your bank should consider filing a DEP form to record Bank A as an exempt person under the Phase I exemption rules. Banks are exempt by regulation, and all you need to do is file the exemption.

Check with your BSA officer to determine whether an exemption might already be on file for the other bank. If not, ask the BSA officer to take care of it for you.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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