For CTR purposes in relation to Item # 13 (Occupation, profession, or business), it says "If known" on page 3. Does this mean if we do not know it is appropriate to leave blank?

“Chance favors only the mind that is prepared”. Louis Pasteur

While the instructions to the paper/legacy Form 104 say "if known" and the instructions to the Form 112 do not indicate the field is required, the apparent flexibility is an illusion. Examiners routinely criticize banks for leaving the field empty or even failing to include a former occupation if the individual is retired or unemployed.

The best rationale for that criticism is: If the person is a customer, basic due diligence would suggest the bank should know the person's occupation. Even if the person is not a customer, all the bank has to do is ask.

Our bank was recently criticized because we had 4 instances in the past twelve months where we did not have an occupation. Each incidence was a non-customer cashing an onus check. We file approximately 300 CTR's a month and was astounded by this criticism. In the end, we convinced them to remove it from the report, but it does demonstate what Ken is saying in that it's an illusion that you can leave the field blank, or use unknown.

And the only "cure" on a going-forward basis is to retrain tellers to remind them of the requirement to obtain the information when they know they have to complete a CTR.

The innate value of reporting information that cannot be verified is demonstrated by the example of a non customer cashing a check who told the bank his occupation was "drug dealer." I told them it was a clear case of testosterone poisoning, but they should write it down and go on to whatever was next.

What about a reportable cash deposit made to a joint account?

Customer 1 and Customer 2 have a joint account. Customer 1 deposits $15,000 into the account without the presence of Customer 2. Customer 2 must be listed on the CTR but we do not have her/his occupation. Can we leave it blank in this case or should we call Customer 2 to obtain the info?

I'll make the obvious statement first: Couldn't the teller have asked Customer 1 about Customer 2's occupation? If they share a joint account, it would seem reasonable that they would know something about each other.

You should endeavor to submit a complete CTR, so you should at least make an attempt to contact one of the customers to get the missing information. If that fails, report that piece of information as "unknown," retrain your teller, and move on, I think.

You can also try to determine occupation from customer 2's payroll deposits into the account, if any. Also check your account opening docs and see if it was noted anywhere when the account was opened.

Thanks!

As John notes, it would have been appropriate for the employee completing the form to ask the occupation of the "missing" account holder.

Going forward, obtaining information on each owner's occupation would be the most minimal of due diligence efforts at account inception. (It's not a legal requirement, but it's the first piece of due diligence information you should obtain after the country of residence.)

"Occupation" is not a required field on the Form 112 and if you do not know what it is you leave it blank. "Unknown" is a prohibited entry.

Thanks, Ken, for clarifying how "occupation" works on the FinCEN CTR. Leaving it blank is the equivalent of "unknown."

We were also recently criticized for having 'retired' instead of retired and then the profession.

I had hoped that migration to the new e-filing formats would do away with that ridiculous idea, but old habits (and old examiners or auditors) die hard, I guess. I cannot imagine what benefit law enforcement might glean from knowing whether such an individual is a retired bank teller or retired physicist. As someone much wiser than I has suggested, the mere fact that the individual is retired ought to be sufficient for LE to detect that a given cash transaction is or isn't worthy of note.

Apparently, the DOL lists more than 800 different occupations, John. With the information regarding the individual's former source of income, law enforcement can tell which one of those 800 the cash did not come from. They can probably rule out "astronaut" with an equal amount of confidence. Thus, they have narrowed it down to 798 possiblities.

As you indicate, the issue is the fact that the person is unemployed or retired and, even though he has no visible means of support, he has more than $10,000 in currency. It doesn't make a nickel's worth of difference what his former occupation was; the due diligence issue is what he's doing now.