If our customer deposited money into his account over $10,000 and then someone else deposited money into the same account, would we check conducted on on behalf as well as list the other person in section b?

Thanks,

Did the other person deposit cash >$10,000? If not, I would check multiple persons, multiple transactions, conducted on own behalf and put the name of the person in Section A who did deposit $10,000 +.

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

Both individuals are identified.

Assuming both deposits are cash and made on the same business day, with a new CTR ("Form 112"), your customer is a person who conducts a transaction on his own behalf and the other individual is a person who conducts a transaction on another's behalf.

Using the legacy CTR (form 104), you check multiple persons and multiple transactions in Item 1, complete a Section A entry with your customer's information, and in section B you check "conducted on own behalf" and provide information on the second person in the rest of Section B.

John, what is the best way to handle this if the individuals conducting the transactions come in at separate times? If they come in together, then you can ID them. If hours apart, not so easy. Thanks.

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

Clearly you have no excuse for not identifying the account owner who deposited over $10,000 in cash. In some banks, the second deposit would not be recognized as something that needed to be reported, and no aggregation would take place. In other banks, the fact would be recognized on the day after the transaction, when overnight aggregation reports are reviewed. At that point, unless the teller can remember who made the second deposit, and you have information on that individual, you'd have to try contacting your customer to see if he/she can provide identifying information. If you can't get complete information (or get none at all), you'd have to check the "multiple deposits excuse box" in Section B of the legacy CTR.

In yet other banks, the second transaction would get "flagged" at the teller line because of the earlier cash transaction, and the teller would be notified to collect CTR identification information from the conductor.

There's no regulatory requirement that you use technology to assist with aggregation. But if you have the capability and don't use it, your regulator can and will cite you for a violation.

Thank you so much!