I have 3 BSA questions, that I'd like some additional thoughts on.

We have an account with 2 living owners and a deceased owner. It is not bank policy to remove the deceased from the account unless/until a request is made by the survivor(s). A deposit was made that triggered CTR filing. Logic says that the deceased owner does not benefit from the deposit and that it was not made on his behalf, and that as a result we are under no obligation to include his information as part of the CTR. However I learned a long time ago not to apply logic to compliance. Should I also include the deceased as part of the CTR?

What do you do if a customer makes a deposit that triggers CTR requirements but they do not have a driver's license or other legal ID? My wife has lost her driver's license once or twice since we've been married and had she taken a deposit to a bank she would not have been able to supply it to satisfy BSA requirements.

If someone completely refuses to cooperate and supply information required by BSA what do you do? Do you refuse to accept a deposit for one of your better commercial customers if their employee refuses to give a SSN and provide ID?

TIA for all thoughts on these matters.

In my opinion:

1. A deceased person cannot benefit from a CTR reportable transaction.

2. I would not process the transaction unless I obtained all of the necessary information to complete the CTR accurately.

3. I would refuse to process the transaction. When ever I have a situation like this, a quick call to the owner resolves the problem 99% of the time.

1) Your logic works in this case- since the deceased customer no longer exists, that person is incapable of benefitting from the transaction, so the deceased person shouldn't be listed on the CTR. (I recommend revisiting that policy about deceased people on accounts- but that's a topic for another discussion.

2) If you have a record of any ID that had been previously used to identify the customer (such as at account opening), you may rely on that instead of asking for the current iteration of the customer's ID every time.

3) We refuse the transaction.