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#1769551 - 12/20/12 09:36 PM CTR - Courier Information (Private)
Banker Chick Offline
Junior Member
Joined: Jul 2006
Posts: 37
TN
Hi,

Just wondering if any of you have provided any reference material to your business customers regarding the requirements to obtain ID information on couriers that are contracted by the customer (NOT the Bank)?

We are getting requests for more information from our corporate customers. What specific reference did you provide to them if any?

Thanks, smile
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#1769603 - 12/21/12 11:05 AM Re: CTR - Courier Information (Private) Banker Chick
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
Acceptance, not direction, is usually the problem.

FinCEN Pamphlet

FinCEN Armored Car Ruling

The Armored Car ruling goes around the barn twice on the way to the house; you may have to highlight the relevant sentence(s). The pamphlet is more clear and equally applicable where the person conducting the transaction is a non customer acting on someone else's behalf.
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#1779964 - 01/25/13 06:06 PM Re: CTR - Courier Information (Private) Banker Chick
RFBanker Offline
Member
Joined: Jun 2006
Posts: 73
I may have missed something obvious. We have several commercial customers who privately contract with armored car services to deliver their deposits. Do we identify the armored entity as transactor or the specific armored service driver?

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#1779989 - 01/25/13 06:52 PM Re: CTR - Courier Information (Private) Banker Chick
Little Miss BSA Offline
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Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
I believe it is the driver you have to identify as the conductor.
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#1779999 - 01/25/13 07:12 PM Re: CTR - Courier Information (Private) Banker Chick
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
The conductor of a reportable transaction cannot be anything other than an individual.
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#1780002 - 01/25/13 07:21 PM Re: CTR - Courier Information (Private) Banker Chick
RFBanker Offline
Member
Joined: Jun 2006
Posts: 73
Thanks for your responses.

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#1780119 - 01/25/13 11:24 PM Re: CTR - Courier Information (Private) Banker Chick
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Some of the larger Armored Car Carriers have actually provided banks with formal letters stating they have instructed all their employees not to provide their information.

I believe this is discussed somewheres on this message board ....
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#1781256 - 01/30/13 06:27 PM Re: CTR - Courier Information (Private) Banker Chick
Juby Offline
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Joined: Jul 2009
Posts: 218
What do you do if the carrier tells the employee not to provide the info? Do you refuse the transaction?

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#1784050 - 02/08/13 12:08 PM Re: CTR - Courier Information (Private) Juby
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Please call the Helpline with that question. They have a canned response. (It does not involve filing a SAR.) I would tell you what their response is, but getting it from me does not help you; you need a memo in the file saying you spoke with them.

Although this has been an issue since July of 2009, I have never heard any anecdotes from bankers who said their examiners looked at it. They know it's a tar baby. I had one client bank whose independent examiner wanted to make compliance with the armored car ruling an issue. The bank recognized the criticism for what it was, the only thing they could find, and suggested they were not paying the auditor for a game of trivial pursuit. It was redacted from the report.

The armored car ruling remains a joke without a punchline.
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#1787168 - 02/19/13 02:39 PM Re: CTR - Courier Information (Private) Elwood P. Dowd
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
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.
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#1787189 - 02/19/13 03:20 PM Re: CTR - Courier Information (Private) Cape Codder
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
Thank you.

Quote:
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.


So banks would aggregate based on the name of the company contact? All cash transactions by "Rufus Armor" on the same day would go on the same CTR? They're probably going to want to work on that "solution."

The armored car ruling remains a joke without a punchline.
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#1791573 - 03/05/13 07:35 PM Re: CTR - Courier Information (Private) Banker Chick
Getting_Grayer Offline
100 Club
Joined: Oct 2007
Posts: 191
USA
Has anyone heard about the guidance being released?

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#1791575 - 03/05/13 07:37 PM Re: CTR - Courier Information (Private) Banker Chick
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,310
Illinois
It was discussed heavily at Top Gun this year. FinCen hopes to issue some revised guidance before the next anniversary of the guidance on July 2nd.
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