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#1842051 - 08/13/13 04:10 PM CTR + ATM w/d
_erica_ Offline
Junior Member
_erica_
Joined: Feb 2013
Posts: 29
Margaritaville
Customer did several withdrawls on Monday aggregating over 10k.

CTR completed.. howver on Friday evening they did an ATM w/d for $200.. the branch balances the ATM at 2 pm, so it posted on Mondays business. Should the 200 be included on the CTR?

Thoughts - any guidance? Much appreciated. I am leaning towards yes, due to the fact it was all on Monday's business, and it somewhat similar to if they made the w/d on Saturday, but would like opinions.

Thank you!!

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BSA/AML/CIP/OFAC Forum
#1842081 - 08/13/13 04:46 PM Re: CTR + ATM w/d _erica_
BC78a Offline
Gold Star
BC78a
Joined: May 2006
Posts: 311
New York
If it is after your cutoff, it should be in Monday's CTR
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Just my opinion for what it is worth

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#1842118 - 08/13/13 05:35 PM Re: CTR + ATM w/d _erica_
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Concur. Monday's posting = Monday's CTR
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1842139 - 08/13/13 06:11 PM Re: CTR + ATM w/d _erica_
_erica_ Offline
Junior Member
_erica_
Joined: Feb 2013
Posts: 29
Margaritaville
Thank you guys!

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