Bank President took $25,000 in cash from a bank internal account for employee benefits. Does this require a CTR to be filed?

What kind of benefits are paid in cash?

Hopefully a bonus

Yes, a CTR is required. I assume whatever cash he is handing out is controlled, documented, and added to the employees W-2s.

Sounds a little hokey to me.........

And if it is for something like bonuses, the bank would be benefiting and he would be conducting? Or would the employees be benefiting and he would be conducting? What if no one person benefits over $10k?

So would the CTR be completed as President on behalf of the Bank?

We had a similar situation where an officer took out a $25,000 for "christmas cash" to the employees. Are you saying we should have filed a CTR?

I don't think it matters who actually benefits from the cash particulary of 10k, Im just wondering if the Bank goes in Part I Section A person on whose behalf transaction is conducted and the Pres goes in Part I Section A as person involved in the transaction? Im hoping for an exemption somewhere, since a bank is involved?

There was one person conducting the transaction, therefor a CTR is required. Techically, each employee that received part of the money goes into Section A as beneficiaries. This is not the way to handle a Christams bonus situation.

Yes I agree, but I'm probably not going to argue with him about it. So the Bank name is not reported?

The Bank is not getting the money, the employees are......

OK, after sleeping on this, this might be just an internal transaction of the bank and not require reporting, but I doubt that you will find any actual guidance,

That's the way I'd look at it. Removing the cash from the teller line but keeping it under control of the bank doesn't IMO create a cash transaction for reporting (bank had it, bank still has it). And the bank completes each of the individual transactions, presumably none of reportable size.

I'd make an argument you don't have a CTR thing going on.

That's where I was going with my thoughts. Unless one person obtained cash IAO $10k or more, I would think no CTR is required. Not the best idea ever hatched by management and definitely could present problems if identified by an examiner that decides a CTR is required. I would probably contact FinCEN for guidance to proactively document my files.

Spoke to FINCEN this AM. Was told "yes" a CTR needs to be completed with the employee that withdrew the cash as Part I Section A On Whos behalf transaction was completed, with Section B box e checked Conducted on own behalf. Now if any one individual employee recieves more than 10,000 in cash that employee would be included as a multiple person. Also, box #35 would not be checked including account numbers affected, however #36 would be with a description of withdrawal for payment of employee bonuses.

I still think it isn't needed, but I am not surprised. What a waste of time. I'll bet they think twice about doing THAT again!

Interesting advice from FinCEN. So if the bonuses went to 30 different people, one of which did really well and received $11,000, that one person would be listed on the CTR with the president in section A and not the other 29? Isn't that like saying if I deposit $15,000 into my individual account and $1,000 into my joint account with my husband, I shouldn't report my husband because he didn't benefit from more than $10,000? Seems to contradict all of the guidance.

I agree with the others that it's not even reportable in the first place, and I find the way that FinCEN said you should complete the CTR to be very odd.

My thought on adding an employee on the CTR that recieves over $10,000 of it is odd because when a customer comes in and withdraws the same amount for example we don't ask where it's going and how it's going to be split up. Why now?

I bet a dollar to a donut if you called them back you and asked the same question you would get a different answer as it sounds like someone made this up on the fly.

I wouldn't take that bet because I suspect you are absolutely correct!

Darn, it was not for employee bonuses. I have another call into FINCEN for further clarification and guidance.

Like a few of your respondents, I'm old enough to remember getting bonuses in cash. I would have assumed that banks just don't do that anymore and if they did, there would be dual control over the withdrawal and distribution of the funds.

However, now that you say it wasn't for bonuses, I'm wondering if you are working with the wrong acronym. Maybe "SAR" would be more appropriate.

Someone with the right title needs to simply ask the CEO what the money was for.

So here's the response on the second go around with FINCEN. I eventually was told that the cash was withdrawn for employee benefits, therefore because it was being held internally, no CTR was required, unless one or more of the employees recieved over $10k and the bank had knowledge at the time of the transaction, then I would file a CTR on the individual(s) that recieved over 10K and the President in Section B as conducting on behalf of. I too am old enough to remember bonuses in cash, Ken. LOL