This recently came up for me in my new job. While reviewing CTRs I noted that there was an on-us check cashed. It was written by Dad to Son. Son came in and cashed it. This is done several times per month. It was always my belief--and my previous banks never had an exam or audit issue around this-- that the account number would be recorded since it's an on-us check. Doesn't matter if Son is a customer or not. (If it's a transit check, no account number.) Lo and behold, it would appear my new bank has not been doing it that way. Since the only clear instructions I can find are an FIL from 1995, I contacted FinCEN to ask and haven't heard back. I'm not anticipating them telling me anything different from the FIL; however, one never knows, as they seem to tell one bank one thing and another bank something different (based on my interactions with them through three different banks).