We have a grocery store customer who is an agent for a large money transmitter. The customer offers no other MSB services and is otherwise not considered an MSB other than being an agent of one for this purpose.
Is there any prohibition to exempting them from CTR reporting? Is it generally acceptable to exempt these agents from CTRs?
When filing a check-fraud SAR, do we have to report all names on the checks, if we are not sure if they are victims or possible suspects, in the subject information section?
We have a customer cashing three large checks (over $10k each) for three different people, all drawn on the same account. Do I complete three CTRs, or one CTR with three "on behalf of" pages, one for each person?
Is a custodian of a minor's account considered a person on whose behalf a reportable transaction is completed on a CTR? We have a situation where someone came in and deposited over $10,000 into the minor's account. The conductor is neither the minor or the custodian. I know that we have to include the conductor and the minor on the CTR. But do we have to include the custodian?
A DBA account owner withdrew over $10,000. The account is under the owner's Social Security number. The tellers said the transaction was for personal use. Do we include the DBA information on the CTR?
I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
What is the proper way of reporting the beneficiaries of the following cash
in deposits in a CTR. The TIN number for all is the same #11-1111111.
XYZ Corporation (6 accounts*) $11100
XYZ Corporation dba Café,LLC (Acct 9999) $1000
XYZ Corporation dba Bake LLC (Acct 888) $600
* There is no dba in the title of the 6 accounts.
Do I need to report 3 beneficiaries to show the actual amount of cash deposited to the accounts?
Is it okay to report XYZ Corp dba Café LLC (6 accounts including acct #9999) $12100 and XYZ Corp dba Bake LLC (acct #888) $600?
Must the CTRs be combined if one corporation owns two DBA accounts?
During new hire training the question was asked, If a transgender person conducted a transaction which required a CTR, what should be marked for the gender? The thought process was, if the customer identifies with the gender not marked on his or her state ID or driver's license, which do we select? My thought is to choose unknown, even though we never use that option otherwise.
When filing a CTR on an IOLTA account, do I need to include the benefiting client's information on the CTR if the Client is incapacitated?