Tentative update on this subject from last Friday's "ABA's Money Laundering and Terrorism Issues Update":
CTR Filings for Armored Car Deliveries
As the March 31 deadline for converting to the new CTR format approaches, many bankers have raised questions about how to report large cash transactions received by armored car. Bankers who have contacted the FinCEN helpline have been getting conflicting information about what to do, although most recently the recommendation has been to contact the armored car company to request an e-mail explaining that drivers will not provide personal information. The instructions for the new form resurrect a problem that has been outstanding for a number of years but had been dormant until the CTR format was revised. This issue has been extensively discussed by law enforcement, banking regulators, armored car companies and FinCEN. A solution proposed by the armored car companies that seemed to satisfy the needs of law enforcement and which was generally endorsed by all concerned was to have banks report the name and contact for the armored car company and not the driver. At the ABA/ABA Money Laundering Enforcement Conference last November, the FinCEN Director of Regulatory Policy announced that guidance would be forthcoming. ABA has been in contact with FinCEN very recently and we hope to see something shortly. If any bankers encounter problems or challenges, please contact Rob Rowe.
Nothing difficult is ever easy.