This is in regards to the Bank Secrecy Act, Administrative Ruling 885, CTR Filing requirements for Armored Car Transports of Currency. My question is What if a Armored Car Service collects currency from our Correspondent Bank for our customer, and the Armored Car Service delivers the currency directly to ATM machines. The currency is never received by us or by our customer. Does a CTR have to be filed?
by Ken Proctor, Director of Risk Management, Brintech, Inc.
Based on 31 CFR 103.22(c)(2), multiple currency transactions shall be treated as a single transaction if the bank has knowledge and result in either cash in or cash out totaling more than $10,000 during any one business day. Does this mean that if Customer A deposits (cash in) $9,000.00 in cash and cashes (cash out) a check for $1,500.00 on the same day, the single transaction totals $10,500 and therefore, a CTR is required?
There have been several times in the last three decades when the ethical behavior of financial institutions has been the center of attention.
We have transactions over $10,000.00 that do not involve currency but are posted as cash deposits for immediate credit to customer's account. Is this a CTR violation?
I recently visited a retail chain that issues credit cards, and noticed a sign posted near the payment center. The notice stated that beginning April 11, 2003, the retailer would be required by the Federal Government to implement a $350.00 limit on the amount of currency it could accept as payment on a credit card account during any 30day billing cycle. Apparently, this change is part of the USA PATRIOT Act. Could someone tell me where, or in what section of the USA PATRIOT Act is this limit is mentioned?
We are required to list the address of the OCC on our Adverse Action letters. Our current letter shows a Houston address. I have been told that the OCC has changed address and we may be showing an incorrect address on these letters. Someone in the office feels they should be going to Washington DC or Seattle.
As part of our BSA Exam we are being questioned about Customs Form 4790. Examiners are indicating that we should be filing this form for foreign wires over $10,000. The form indicates that individuals should file this form. What are banks obligations in regard to this form? Are there special forms or procedure that need to be followed for wires out of the country. Are there special rules under OFAC or the PATRIOT Act?
Predatory lending has been front and center for several years - and it is staying there.
We have been informed that required records to be retained for BSA compliance including credit slips for loan payments, money orders, etc must show the amount of any currency involved.Is this, in fact, a requirement of BSA rules?