Concealing CTR Filing from the Customer

by Mary Beth Guard, BOL Guru

Question: Are Currency Transaction Reports supposed to be filled out in front of the customer or should we wait until the customer leaves?

Answer: Unlike Suspicious Activity Reports, CTR filings do not have to be concealed from the customer. It is perfectly acceptable, and legal, to let the customer know that a CTR filing is required, and it may even be necessary to reveal to the customer that you are filing a CTR if you need to ask the customer a lot of questions in order to complete the form, just so they understand why the questions are being asked and why this transaction is being handled in a different manner than previous transactions.

The original version appeared in the June 2004 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 11/8/04