Skip to content
BOL Conferences
Thread Options
#1796103 - 03/19/13 01:48 PM New CTR form and currency exchange
ecrew,CRCM Offline
100 Club
ecrew,CRCM
Joined: Apr 2010
Posts: 204
Fl
If we a person bring in $11,000 for a cash deposit for a business, and $300 to exchange for smaller bills would we do the following:

Part I
Person conducting transaction for another: cash-in $11,300
Person on whose behalf transaction was conducted (the business): cash-in $11,300

and then in Part II, Line 25 Deposit: $11,000 and Currency exchange $300.
_________________________
Nevermind tomorrow, TODAY is the day. -unknown



Return to Top
BSA/AML/CIP/OFAC Forum
#1796362 - 03/19/13 07:47 PM Re: New CTR form and currency exchange ecrew,CRCM
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes. That's correct. You would not show the cash-out half of the currency exchange at all, because total cash-out is not more than $10,000.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1800424 - 04/02/13 02:58 PM Re: New CTR form and currency exchange ecrew,CRCM
ecrew,CRCM Offline
100 Club
ecrew,CRCM
Joined: Apr 2010
Posts: 204
Fl
So we would still show the money being exchanged on the business even though it does not affect the business account itself.

I'm being asked this and I say yes because it still affects the business because it's for the business and we need to list an account number for the business.
_________________________
Nevermind tomorrow, TODAY is the day. -unknown



Return to Top
#1800447 - 04/02/13 03:33 PM Re: New CTR form and currency exchange ecrew,CRCM
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The reason you list an account number in your case is because there's a deposit being made that is also being reported. If the business hypothetically exchanged $11,000 in $100 bills for $11,000 in $20 bills, no account number would be listed in item 21 because no account is affected by the exchange. But you would list $11,000 as the cash amount for both items 21 and 22.
Last edited by John Burnett; 04/02/13 03:34 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z