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#1584744 - 07/28/11 06:39 PM Should we file a CTR?
MSMITH10 Offline
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We currently have a business customer with several accts. The runner for this company will bring in a check made out to cash drawn on one of the company accts. The check will be cashed by the teller, but never given to the customer. The cash then gets deposited back into the same business account it was cashed out of. We are working on a "why", but in the meantime would a CTR need to be filed? The customer is never handling any cash.

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#1584761 - 07/28/11 07:03 PM Re: Should we file a CTR? MSMITH10
AFaquir Offline
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So the customer writes a check against the account and then deposits it right back in for cash? I'm very confused... Is there a delay in the timing for withdrawal and redeposit?

If there is a delay in timing to me this isn't a CTR, but a SAR with pretty strong leaning towards classic money laundering...

For me the scenario plays out like this... Pablo Escobar wants a front for his drug business. He uses cash, he needs cash, he wants to earn interest on his cash not in use. He starts a company in the name of Ramon Escobar called NottaDrug Front, LLC. The customer doesn't do business in cash, but is a legitimate company. Pablo brings him cash to deposit... which he does and in return he gives Pablo the cash from the account by sending the runner (hoping you won't file a CTR, but if you do its against the business and you have the runners info further hoping it goes unnoticed). This way, Pablo's dirty money ends up just clean and dandy in the bank... and ready for him to access whenever the FBI/ATF/DEA come for him.

If there is not a delay, then I have no earthly idea why somebody would go through this excercise except boredom or to start to establish a pattern of activity so that they can later begin doing suspicious stuff.

To answer your question, the use of a runner doesn't mean that a CTR shouldn't be filed. We have a similar situation with a customer of ours, but the money leaves the bank and doesn't return in cash, so it is slightly different... I would say file a CTR if it is over the threshold and the money physically leaves the bank for any length of time.

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#1584800 - 07/28/11 07:22 PM Re: Should we file a CTR? AFaquir
complylady Offline
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Joined: Jul 2002
Posts: 614
Sounds like some sort of weird recordkeeping. Have seen customers come in and deposit cash and then make a withdrawal in cash with the reasoning that for recordkkeeping they need to deposit the money. But this is strange. I agree no CTR as the oney did not cross the counter or leave the bank. I would have the teller ask the customer - tellers can find out a lot with casual conversation

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#1584803 - 07/28/11 07:22 PM Re: Should we file a CTR? AFaquir
MSMITH10 Offline
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Posts: 160
ABC Inc sends in a $15,000.00 check made payable to cash off of acct 123456. This check is cashed by the runner. The $15,000.00 in cash is then deposited into the same acct 123456. Cash is posted immediately, and checks are credited next day. I have thought of this purpose. I have asked the acct officer to question the activity.

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#1584931 - 07/28/11 09:45 PM Re: Should we file a CTR? MSMITH10
ackcompliance Offline
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Posts: 139
Yes very strange activity. We had very similar incident. The customer actually walked out of the bank with the money and then came back later that afternoon with the same amount and deposited it back into the account. In that situation we filed a CTR for the cash in and the cash out, but I wouldn't think that your situation requires a CTR necessarily since none of the cash left the bank but how would you prove that with a cash out and a cash in transaction unless they are just within moments of each other?

Maybe it is a test for the runner, to see if they will run off with the money? Or maybe they were supposed to take cash back to the company because they needed it. Who knows. But if it is suspicious, I would definitely file a SARs or at least document the activity.

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#1585104 - 07/29/11 02:27 PM Re: Should we file a CTR? ackcompliance
Sing A Little Offline
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If the cash never left the bank I don't think I would file a CTR, but I would make sure you document the situation for any potential audits.

This is a bizarre scenario, I've been customers do this type of thing between accounts before but not with the same account. If it were me I'd set the ground work for a SAR investigation.
He who sings scares away his woes. ~Cervantes

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