We just were notified that there was a miss-match between the messenger’s name and SSN. We called the customer and found out that the messenger does not have an SSN, and the number we were given by the messenger was made up. We told the customer not to send this messenger again.

Today another messenger came in with a cash deposit and when asked for his SSN he told the =teller he has none. The teller took the deposit after being shown a driver’s license. Three questions:

1)How do I treat this on the CTR?
2)Do I file a SAR on the messenger as an illegal alien, or for refusing to give us an SSN?
3)How do we handle the customer?

Thanks in advance

If he has no SSN, document "None" on CTR.

I wouldn't automatically assume that he is "illegal" because he doesn't have a social security number. If, however, he is working then he should have a number. If I determined that hiring undocumented workers was SAR worthy, it would be the employer that would be reported.

For the TIN enter NONE.

I don't necessarily see anything else suspicious.

Thank you both. As a follow-up, it appears that neither of you feel giving a fake SSN is worth a SAR, am I correct? This was the one thing I was sure required a SAR

I would probably do a SAR for the fake SSN since that is clearly a violation. Whether I would a SAR for the messenger w/o an SSN is more doubtful.

Thanks

What you do need to do though, is amend the CTR to remove the TIN that you had (on the one that you found out it was fake) and report NONE now.