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#1820340 - 06/05/13 12:48 PM CTR Issue- Its a doozie...
C.A.L. Offline
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C.A.L.
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We had a non-customer visit a business center 3 times in one day. Each time he cashed an on us check from a local construction company. Once the report was pulled to aggregate the transactions the teller supervisor called the gentleman to obtain his identification information. (The information was not obtained at the time of the transactions because he went to three different tellers and the 2nd and 3rd teller did not know he had already been in.) He refused to give her any information stating that he did not want that "form" filled out, that is why he came in three different times. He stated that he would bring the money back before he would give her the information that she requested. I am at a complete lose as to what to do in this situation...does anyone have any ideas on how we should procede?

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#1820345 - 06/05/13 12:58 PM Re: CTR Issue- Its a doozie... C.A.L.
rlcarey Offline
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Check multiple transactions on the CTR and file a SAR. If the checks were written in sequence, include the construction company in the SAR for aiding and betting structuring.
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#1820352 - 06/05/13 01:09 PM Re: CTR Issue- Its a doozie... C.A.L.
C.A.L. Offline
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That is what I was leaning toward but the only information I have for the CTR or SAR is his name...nothing else.

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#1820388 - 06/05/13 02:06 PM Re: CTR Issue- Its a doozie... C.A.L.
Matt_B Offline
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You can always attempt to ask the construction company for any further information, otherwise you'll probably be filing with a bunch of blanks!
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#1820413 - 06/05/13 02:55 PM Re: CTR Issue- Its a doozie... C.A.L.
rlcarey Offline
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Originally Posted By: C.A.L.
That is what I was leaning toward but the only information I have for the CTR or SAR is his name...nothing else.


So you are telling me that you cashed over $10,000 in checks for a non-customer and never documented any identification??? I think you need to review your non-customer check cashing policies. How do you know that the right person even got the money?? Sounds like you might also be out >$10,000 if payee steps forward and says they never got the money.
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#1820430 - 06/05/13 03:17 PM Re: CTR Issue- Its a doozie... C.A.L.
C.A.L. Offline
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Apparently this guy cashes his payroll checks weekly at this business center so one of the tellers was familiar with him and gave the "ok" to the others to cash the checks with no id.

The company has been contacted and they gave us some of the information we needed but not all of it.

Hopefully these tellers have learned a lesson and this will not happen agian.

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#1820441 - 06/05/13 03:30 PM Re: CTR Issue- Its a doozie... C.A.L.
Kathleen O. Blanchard Offline

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The bank needs to establish and enforce rules to protect the bank, not hope tellers do the right thing.
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#1820442 - 06/05/13 03:32 PM Re: CTR Issue- Its a doozie... C.A.L.
Matt_B Offline
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That also means you should be able to pull some of the missing info from previous checks, hopefully!
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#1820558 - 06/05/13 05:53 PM Re: CTR Issue- Its a doozie... C.A.L.
rlcarey Offline
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"one of the tellers was familiar with him and gave the "ok" to the others to cash the checks with no id."

So what you are actually telling us is that one person was aware that this person was conducting multiple transactions at that branch on this specific day. You have some weaknesses to address.
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#1820561 - 06/05/13 05:57 PM Re: CTR Issue- Its a doozie... C.A.L.
Kathleen O. Blanchard Offline

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I thought the poster might mean that the teller in general said it is okay to cash for this guy, not just on that day.

However, why does a teller get to issue this okay?

Still process weaknesses (but not of the same type if someone was aware of multiple transactions).
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#1820568 - 06/05/13 06:03 PM Re: CTR Issue- Its a doozie... C.A.L.
rlcarey Offline
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Galveston, TX
I would also recommend that the bank refuse to cash any further checks for the guy until he provides you with the information that you need to file a complete amended CTR with all required information. He doesn't really get to choose the game rules in which he has decided to play.
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#1820636 - 06/05/13 06:49 PM Re: CTR Issue- Its a doozie... rlcarey
JacF Offline

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Originally Posted By: rlcarey
I would also recommend that the bank refuse to cash any further checks for the guy until he provides you with the information that you need to file a complete amended CTR with all required information. He doesn't really get to choose the game rules in which he has decided to play.


I fully agree!

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#1820663 - 06/05/13 07:17 PM Re: CTR Issue- Its a doozie... C.A.L.
M Cockrell Offline
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Dallas, TX
Originally Posted By: C.A.L.
...He stated that he would bring the money back before he would give her the information...does anyone have any ideas on how we should procede?

Since he offered, tell him to bring the money back.
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#1820674 - 06/05/13 07:25 PM Re: CTR Issue- Its a doozie... C.A.L.
devsfan Offline
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NYC
Then you would need to file another CTR for the deposit. So you get to file 2 CTRs and 1 SAR and have better things to do I am sure.

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