I think I remember seeing this topic previously, but I am unable to find it.

A husband and wife operate a trucking business; once a week the wife comes into the Bank and cash multiple foreign (not our FI) checks that are all payable to herself personally. She is receiving the funds herself but has expressed that the funds are being provided to employees for payroll. Should we have an instance when we have to file a CTR; the wife is the transactor, but are we required to include those employees who are receiving cash as benefactors as well?

Thank you!

The fact situation you are thinking of is when one person (employer or otherwise) comes in and cashes several payroll checks on behalf of people who are not present. In that circumstance, it may be necessary to list each payee as a person on whose behalf the transaction was conducted.

That's not your situation. What she says she is doing with the cash makes no difference. As the checks are payable to her, she's cashing them on her own behalf.

This is not a garden variety transaction...if the checks appear to be in connection with her business she should be depositing them to the business account...

Thanks Ken - that is where my thoughts were, but it helps to get a second opinion!

Why is your customer bringing multiple (payroll) foreign checks that are all made payable to herself and not made out to the individual employees? Why not cash those checks from the issuing bank? As for the CTR, only the transactor's information is required, as there is no evidence that the employees will be benefiting from the transactions. I'd definitely look further into the motive of conducting transactions in this manner.

Yes, we are looking at the activity on the SAR side as well.