Does anyone know anything about using Smart Safes?

When a customer uses one of the these and the cash goes straight from them to the armored car service is the bank responsible for completing CTRs for these cash transactions even though the cash never made it to the bank? I feel like I am over processing this but I don't want to miss anything.

There is or was a real old guidance document issued by FinCEN that deposits to such a centralized fault arrangement does not exclude the bank from CTR filing responsibility. Maybe someone else can put their fingers on it.

I can't find it either, but agree that it clearly indicated that the bank's CTR filing responsibilities did not go away based on the fact that the bank never had physical possession of the cash.

Thanks for the help...I actually found the guidance that rlcarey was referring to (FIN-1988R005) and I also spoke to FinCEN.

Nothing changes as far as the completion of the CTR.

That ruling [FIN-1988-R005] addresses situations in which the contractual agreement is between the bank and the armored carrier that takes the cash from customers' deposits, processes it, and deposits the cash with the Fed on behalf of the bank.

Is that what you mean by a "Smart Safe" service?

Yes

We have a slightly different arrangement. We have contracted with WFB to have our customer's cash deposits processed by their cash vault; however, WFB prepares CTRs. Our correspondent account is credited. We debit the correspondent account the next day and credit our customer's account for the cash deposit.

I previoulsy posted a question about monitoring these customer's accounts for suspicious activity. Since they are cash intensive, you will have to develop a separate system to monitor the activity; or manually input the transactions to your AML software so that you can monitor them just like any other customer.

There is different old guidance I believe for this situation as WFB, I assume is Wells Fargo Bank, which is a financial institution while Brinks/Looms is not. Both FIs are responsible unless one is responsible via a contract between the FIs.