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#1833381 - 07/16/13 07:12 PM CTR on UTMA
parr04 Offline
Gold Star
Joined: Aug 2004
Posts: 394
oklahoma
Person deposits reportable cash into three different accounts. One is a UTMA account on which the depositor is the custodian. When the account was opened we did CIP on the custodian not the minor child.

How do we complete item # 20 on a CTR since the owner is a minor and we did not do CIP on him when the account was opened?

I also understand this could lead to a SAR filing.

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#1833390 - 07/16/13 07:20 PM Re: CTR on UTMA parr04
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Since you most likely don't have any identification on the minor, this would be an instance when you would check the "Unknown" box.
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#1833779 - 07/17/13 07:37 PM Re: CTR on UTMA parr04
Ben22 Offline
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Joined: Jul 2013
Posts: 15
I have this posted on another thread, but what about if we have a check made out John Smith custodian for Ben Smith Uniform Transfers to Minor. The custodian, John Smith, is a customer of ours, but the UTMA account is not held here. The check is from Edward Jones I believe. So, of course we have John Smiths info but we do not have the minors info. Should we just check the "Unkown" box as well?

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