So a teller gives cash out (over $10k) to a customer. Customer opened his account in 1992, so no ID is on file because we didn't require it back then.

We don't ID customers that we KNOW- so no ID was recorded in the system. And the teller did not fill out a CTR so she didn't ask for the ID.

The customer went on vacation and we cannot reach him via any phone numbers in our system.

This happened early last week. I am nearing the filing deadline.

Do I file and then amend once we can get the ID info? We know the customer will be back in and we have notes all over the account, but we are not sure if he will be in a branch prior to having to file the CTR. I am sure an amendment would be better than a late filing...right?

If the I.D. information is the only thing missing, I would file then amend once the customer came back into the branch.

You may have done this already, but I've found someone's ID (more than once) by reviewing checks that cleared the customer's account. At some points of sale, when the customers write a check, the cashier's document the DL number. It was tedious going through checks in the system, but on more than one occasion has been helpful.

That is a great idea! Thanks for sharing!

Seems to me you have a severe weakness in your teller processes or you need to do something (about this teller) to make sure this never happens again. In this day and age with the sophistication of teller platform systems, how could a CTR be bypassed?

Our system is from the stone age...it does NOT prompt for CTRs. The teller is a seasoned teller and knows better. We do training on this all the time, discuss it at every monthly meeting, etc. But out of 25 CTRs so far this year (we are very small), I have had to call and ask for 3 of them because they were never sent to me. The tellers know they have to do it- they just don't and there is no accountability. I am held accountable- but unfortunately I am not given the authority to hold them responsible...

Time to move on? Sounds like you have the skills...............

I appreciate the thought! But I still do have a lot to learn in order to keep pace with the big boys!

I will just add this to my airing of grievances for now...

I would not tolerate working for an employer who holds me accountable for compliance with a Federal regulation as deadly serious as the BSA but who doesn't give me the authority to enforce branch procedures. Just sayin'.

easy to stand on your principals when you don't need to...but the way the job market is right now, many people are putting up with "stuff" that 10 years ago they would have laughed at and walked across the street for another job...

I agree that things are such that you can't simply walk out...but this is the kind of issue that would start me down the path to looking for something else, particularly since it can take some time to find something.