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#1610480 - 09/29/11 02:37 PM Aggregating cash transactions
AuditorK Offline
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Joined: Feb 2003
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PA
We have the normal daily system reports that aggregate cash transactions by the TIN associated with the account number the transaction is processed to during imaging.

Where we are lacking is in currency exchanges. These tickets are run as a straight cash-in/out with no account number to associate to. This causes some missing transaction information on my daily report.

Example: Sally brings in a $9,200 cash deposit for ABC Inc. As a seperate transaction, she brings in $1,000 in twenties to be exchanged for ones - for change for the business. My report captures the $9,200 under ABC Inc. The $1,000 doesn't show. Unless the teller recognizes this, no CTR is completed.

If I instruct the tellers to run the currency exchange tickets with the business account number on, this should solve my problem - correct? Or should the tickets have the TIN of the person conducting the transaction (Sally in this case)?

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#1610512 - 09/29/11 02:56 PM Re: Aggregating cash transactions AuditorK
BrendaC Offline
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BrendaC
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Sweet Home AL
It should, but your results will depend solely on your systems. You will need to run some tests and verify your output understand how you need to modify your procedures and processes.

Sometimes, you can simply input the account number into the system without running any special tickets. Again, depends on the systems involved.
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#1610520 - 09/29/11 03:01 PM Re: Aggregating cash transactions BrendaC
AuditorK Offline
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Am I correct in my thinking that when someone conducts business on behalf of someone else (like in my example above), the account number/TIN should be of the person benefitting from the transaction - not the conductor?

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#1610538 - 09/29/11 03:11 PM Re: Aggregating cash transactions AuditorK
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
Some banks capture the info on people conducting cash transactions over a certain amount (such as $3000) to enhance their ability to fully complete CTRs. We used to do that at the bank I worked for when we were on JHA Silverlake system and used the JHA Vertex teller system.

If I am having to take steps to trigger a system to capture info, I would be more interested in the person on whose behalf the transaction is being conducted than the transactor if I had to choose one or the other for smaller cash transactions. You can always check "multiple persons" if a CTR is triggered and you don't know who conducted all of the transactions.
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#1610539 - 09/29/11 03:12 PM Re: Aggregating cash transactions AuditorK
John Burnett Offline
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John Burnett
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Cape Cod
That depends on what you're trying to do. Aggregation is needed based on both the person on whose behalf the transaction is conducted (presumably, the account holder(s)), and on the individual conducting the transaction.

The norm is to connect cash deposits to the holders of the accounts for aggregation purposes. Conductors normally are "caught" for aggregation when they bring in multiple transactions that by themselves require a CTR or when a teller (or some other system) recognizes that the same individual conducted multiple transaction. In my experience, aggregation is usually effective based on the TIN of the deposit account holder and less effective based on the conductor (with the exception of multiple transactions by the same individual at the same time).
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