Customer comes in to the Branch and asks to open a new account for $30,000.00 cash, and counts the money in front of the new account representative.

Before taking the money, the rep asks the customer what the source of the cash was and was told it was a gift. The rep asked for proof of the gift and the customer instead said she would deposit the funds in her other bank and come back with a check (which she did)

Since no bank employee ever touched the cash, do we need to file a CTR?

Thanks,
BC78a

No, you don't need to file a CTR. However, the way the customer responded to the employee's request for verification of the gift may prompt you to consider a SAR.

There's no BSA requirement to request any such "verification." Unless the deposit was associated with a loan transaction or some other similar transaction where you needed to document the source of funds, I don't believe I would have requested such verification, even considering the fact that the deposit was to fund a new account.

No CTR.

Either file a SAR (identifying the bank on which the check was drawn) or leave a note explaining why you didn't. (Such a note would be a lot harder to word than the SAR.)

Your employee did good. I've witnessed a few million dollars in gifts (trust officer). None were in cash.

Thank you both.

Yes, the new account representative did a good job. All our reps are trained to ask about large cash deposits, and if they feel uncomfortable with the explanation, to ask for documentation.