Someone withdrew over $10,000 from our ATM over the weekend using a credit card. We have her on camera and she isn't our customer. How are we going to complete a CTR without the necessary information? Also, as far as we know the card isn't stolen, and it would take a PIN to get cash, but could we be held liabile if the card did turn out to be stolen?

This is the second time within the past few weeks we've had a thread on someone withdrawing over $10k from an ATM. I am absolutely amazed that this is possible. I am obviously a very conservative banker, because I would never allow limits to be set that high on an ATM if I had a say in the process.

Sorry. Back to your question...I would try to contact the card issuer to determine who will file the CTR. If the issuer authorized the WD, I don't know how you could have liability for the transaction.

I guess we weren't aware that our ATM would allow that high of withdrawal limits (since it isn't our cardholder). We are going to get that changed! I didn't think about the card issuer filing the CTR, I wonder if since it's a credit card if they will do that. I'll try and find out though. Thanks.

You and the card issuer are both responsible for filing the CTR, but you can agree between you which will do it. It simply makes sense that the card issuer, which has the needed information, would do the filing, based on your report to the card issuer that their customer pulled over $10K from your machine.

As a matter of fact, it's possible they have already filed it, since they should have received a report that a cardholder obtained such a large cash advance (and it would indicate it was done at an ATM, I believe).

The interesting twist in this scenario is that it was a non-customer that did that with your bank's ATM. We can set withdrawal limits on our customers, and physical limits on the ATMs themselves, but can those be breached by non-customers? See http://blog.wired.com/27bstroke6/2009/02/atm.html for a possibility....