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#1303634 - 12/11/09 04:05 PM CTR Question
parr04 Offline
Gold Star
Joined: Aug 2004
Posts: 394
oklahoma
We have a business owner who sent an employee to cash a check drawn on the corporate account and made payable to cash. The check is for $ 15,000.00 and we have verified the transaction is authorized and valid.

Who would be listed in section "A" Persons on Whose Behalf Ttransaction(s) is conducted of-- the person who gets the cash or the corporation?

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#1303685 - 12/11/09 04:30 PM Re: CTR Question parr04
ComplianceGurl, CRCM Offline
Platinum Poster
Joined: Jul 2007
Posts: 500
I just ran across this very same situation the other day. We actually filed on the person who cashed the check and walked out with the money. I'm curious to see if anyone feels differently.

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#1303697 - 12/11/09 04:38 PM Re: CTR Question ComplianceGurl, CRCM
Steeler fan Offline
New Poster
Joined: Aug 2009
Posts: 12
Michigan
It all depends on who the transaction is really be done on behalf of. If the individual who is in your branch says he is taking the money back to the owner of the business then it appears that the business would be listed in section A. If you know the individual is keeping the money for themself then they would be listed in Section A.

This is a perfect situation where a question by the teller to the individual needs to be asked and that should hopefully provide the answer.

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#1304095 - 12/11/09 09:16 PM Re: CTR Question Steeler fan
ComplianceGurl, CRCM Offline
Platinum Poster
Joined: Jul 2007
Posts: 500
Ok..so I'm going to put on my criminal hat. cool So let's say the check is made payable to cash for $15,000, but I really don't want my name on the CTR as the person who benefited from it. I'll just say it's going back to John Doe at the office. I always thought for CTR purposes the person or persons walking out of the FI is the one benefitting from it?

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#1304168 - 12/11/09 09:57 PM Re: CTR Question ComplianceGurl, CRCM
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Your name will still go on the CTR in Section B as the conductor of the transaction.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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