We have an individual who comes in to make regular cash deposits into one of our cash-intensive business customers. This person is an employee of the business but not a signer on the account. We have been filing many CTRs on this individual with no issues or errors from the IRS. Recently, however, we discovered the SSN we have been filing was issued long before the individual was even born!

Here comes the tricky part - Since the IRS had no issues in the past and, even now, would it make sense to create an issue now? Obviously, the SSN does not belong to the indiviual, however, the IRS seems to be fine with it. What would you do?

Take the appropriate action. Appears you might have an identity theft issue.

File a SAR

I would reverify the SSN to make sure I didn't have it listed incorrectly. If it matches what I had on file, then I would file the SAR.

I'm with Happy make sure its not just s mistake before making an issue out of it. Then act appropriately.