We had a non-customer cash a $4000 on-us check on a Saturday, a day on which we do no processing. The same non-customer cashed a $7,500 check on the same on-us account at a different branch on Monday. Our system aggregates the two transactions and we need to prepare a CTR. We do not have the person's SS# or date of birth for the CTR. Can we file the CTR without this information, or do have to track down the SS# and DOB?

Since you should have some ID on the person you could attempt to contact him/her for the missing info (good luck). You could also ask your customer for some help since there should be some sort of relationship there. If you cannot get the missing pieces of info you have no choice but to file with what you have and document in your files why the CTR is incomplete. You should then review your procedures and systems since the Monday transaction should have alerted the teller about the need to get the information for the CTR on the spot. You should also consider the possibility of structuring and consider filing a SAR.

I agree with devsfan--we have trained Saturday personnel to be sure to get all non-customer information needed in situations like this (tellers take photocopy of driver's license and attempt to get soc.sec.# if possible)as we have run into this sort of problem before where you have a possible structuring situation. Our system uses a $7,000.00 threshold on the teller side which automatically prompts all CTR information to be gathered, but for the smaller amounts we count on tellers to gather the appropriate information for a potential CTR.
As devs said, hopefully the customer has some information regarding the check casher which will help you, but it's often a tricky situation at that point. Definitely document in your files why the CTR is not complete and also document how your bank will be correcting and preventing this problem going forward--this will show the examiner you have already dealt with the issue and you'll be less likely to be criticized.

And to answer your question specifically regarding filing the CTR without the information.

If a reasonable effort to obtain the required information fails and you have to file without it, be sure to include on the CTR all information that you DO have and then mark box d in Section B 'multiple transactions'.

As for your procedures, you will probably want to look at the size of your bank and resources at your disposal to determine what a 'reasonable' effort is for your bank in attempting to obtain additional information in circumstances like this. As long as you have a solid line of reasoning for how far you will go in going after this information, it'll give you a firm grounding when having the 'why' discussion with an examiner.

Our procedures would have called for us to gather that information for the Monetary Instrument Log when the $7,500 check was cashed. Anytime a Non-Customer cashes an ON-Us check for more than $3,000, we gather all information (SSN, DOB, DL#)and it goes on the log sheet. The only piece of information we would not have gotten would have been the occupation.

Our system threshold is $5000 on checks cashed. We have been through 2 exams with this system and the examiners have been satisfied with that level. They know we don't catch everything but that we are trying to comply with the spirit of the BSA laws and do our best.

So, gaj, in your situation, our system would NOT have prompted for the information collection on the Saturday transaction, but would have on the Monday transaction. However, since we depend on our system to aggregate and not on any manual reports (again, with examiners' approval), the system would NOT have aggregated the two together because there was no indentity linked to the Saturday transaction. We would not have filed a CTR because we did not "know" about the first one.

Gaj, do you use an automated system for aggregation and CTR reporting or do you look at reports to know who to aggregate?

I wanted to revive this old thread instead of starting a new one. Want to pick your brains on a related question I have.

How are you all facilitating "aggregation" for non-customers? The OP is a good question and sort of in line with my inquiry. But is there a regulatory expectation behind the BSA for institutions to file CTRs on NON-customers if they have aggregate activity on a day involving different tellers/branches?
We don't collect any PII, only ID info to cash a check (even check payee name doesn't get recorded, only imaged). Our only non-customer txns are check cashing and cash advances. So what if we had a non-customer do a $5500 cash advance at 10am to buy supplies and then cashed a $7500 check to pay for finishing of the job at 5pm? I fully understand if a single visit is >$10k then teller needs to send over a CTR, but how are banks doing aggregation? How on earth can FinCEN/regulators expect institutions to fulfill that....

This is curious. Why do you do this? It seems weird to me, if I was this non-customer, that you would ask for my SSN but not an occupation.

BSA programs are supposed to be risk based. To me that means there is always some room for error. You are not expected to be perfect in all things BSA but you are supposed to do the best you can within the restraints of systems and people.

Are CTR filings risk-based?

No - CTR filings are not risked base and I don't understand AML247's statement either as cashing a check has nothing to do with Monetary Instrument recordkeeping.

CTR filings are not risk based, but capturing data for aggregation is. The requirement to file CTRs when aggregating multiple transactions is based on the institution's knowledge that a CTR is required.

So if a business customer has three different people make deposits throughout the business day that are all under $10,000 but combined exceed the filing threshold, a CTR is required. The institution may not have knowledge that a CTR is required until the next day when someone reviews an automated monitoring system alert or core cash report. The tellers may not have collected information from the individuals making the deposits because by themselves, none exceeded $10,000. We have the "aggregated transactions" box on the CTR for this reason because we may not identify the persons making the reportable deposits.

However, some institutions take a risk averse perspective and decide they will start capturing information from individuals conducting cash transactions at lower thresholds ($3,000, $5,000, etc.) This is a risk-based decision and there is nothing in the BSA that requires this process.

Similarly, asking a non-customer for their social security number when cashing a $3,000 check on the possibility that same non-customer will go do a different branch and cash an $8,000 check is not required and is a risk-based decision.

"I fully understand if a single visit is >$10k then teller needs to send over a CTR, but how are banks doing aggregation? How on earth can FinCEN/regulators expect institutions to fulfill that...."

Most have some type of BSA software that can aggregate. and as BrianC posted "However, some institutions take a risk averse perspective and decide they will start capturing information from individuals conducting cash transactions at lower thresholds ($3,000, $5,000, etc.) This is a risk-based decision and there is nothing in the BSA that requires this process."

But aggregating how? What is it compiling? The teller is just verifying the check payee name to the name on the ID, cashes it, hands over cash, transaction over. Can't even aggregate based on ID number because what if they used a DL at location A and a passport at location B, and so on.
I think if I were a BSA Officer my institution CTR expectation would only be on non-customer transactions >$10k at one time. I don't see any way a regulator or FinCEN could enforce CTR compliance on non-customer aggregation. Seems highly unreasonable.

Most banks that will even cash a check for a non-customer will create a profile in their system for the non-customer - so it is not that hard to track multiple transactions. Many banks will not even considering offer the service. If you choose to do so, you can bet your regulator will expect that such BSA/AML controls be in place.

Sounds sort of like you are either new to BSA/AML compliance or have not witnessed a variety of different BSA/AML programs. Much of what you have to do for BSA/AML compliance is inanely unreasonable.

So so very true!

"Most banks that will even cash a check for a non-customer will create a profile in their system for the non-customer"

This is new to me. Do most banks that cash on-us checks for non-customers create a profile?

I've never heard of that but I guess it doesn't surprise me.

yes, I work for a small bank in the Northeast and if a non customer wishes to cash a check drawn on our bank, the tellers are instructed to create a profile in our system in order to cash the check. This requires the bank to collect their information and if the non customer is reluctant to provide it we kindly request they go to their own bank to cash the item.

"But aggregating how? What is it compiling?" By Customer account number or better by customer CIF.

Transactions without a customer transaction account on at least one side would not be conducted, (at least in NY)


Multiple non customer transactions from different customers accounts are rarely seen. Conduct a risk assessment if necessary.

"Most banks that will even cash a check for a non-customer will create a profile in their system for the non-customer" would be the best in this scenario.

In my experience, the profile is typically built in the teller system and the data is imported into the the AML software being used on a nightly basis. A CTR is not created unless the threshold is triggered and the SSN is used to aggregate.

If your teller system does not capture information on "transactor" or "conductors" then this will not be happening. As a BSA Officer, it is important to have a thorough understanding of your core/teller/AML systems. Your teller system may have the capability to do this, but it needs to be set up and a threshold selected.

As Brian said, technically, this is not required, but many banks do use these features. Non-customers don't like handing over their SSN when cashing a check, so be aware of that. But as another poster said, they are not your customer, so you can tell them to go cash their check at their own bank.