We have a business that cannot be exempted from CTRs due to the nature of the business. One of the owners will come in with cash, purchase a cashiers check, instruct the teller to put someone else's name (non-customer) as the remitter and then immediately deposits the check into the business account. For #25, would you select d-purchase of a negotiable instrument? (I'm presuming that is the correct answer) Or would you select a-Deposits since ultimately the cash is making it into the business account albeit a round about process?

This is interesting. What business are they in? Is it a law firm? I'm wondering why they do this?

They sell boats, ATVs, sleds, etc.

The owners individually do not hold accounts with us so since we do not sell CC to non-customers, the tellers record both the purchaser and the payee as the business (edited to add that they notate which business owner is making the purchase in addition to the business name) in our CC log (and our MI log if it applies). Hence my question - cash comes in the door and ultimately ends up in the business account ... albeit in a round about way. Is the CTR for a "deposit" or is it for "purchase of monetary instrument"? In the end, ultimately, the cash is going into the business account and I want to say deposit but ... ??

and you're okay with this?

They are laundering money - geez. Like Happy said, you are OK with this???

A business cannot purchase a cashier's check using cash - only an individual can do that. Your CTR and MI recordkeeping (if $3,000 to $10,000) is all wrong.

Get your records straightened out and pull out a SAR.

This ^^^^

There is no state law governing this that I have been able to find and, although our policy states we do not sell CC to non-customers, we currently have no policy that addresses/prohibits this practice of naming another remitter on the face of the check. The BOL threads that I have searched on this topic previously seem to be split but ultimately it appears to come down to bank policy.

Usually, when I have seen this before, it has to do with a humongous fraud being perpetuated. Where is all the cash coming from???? Multi-million $ loan schemes involving fake payments and receivables, etc. come readily to mind - let alone the money laundering aspects of such transactions.

You are correct, it is not a State law issue. It basically comes down to banking 101. Pop coming in and buying a $150 cashier's check for junior payable to AT&T us one thing. Customers bringing in sacks of cash and faking who the money is from for their business accounting records - is a whole 'nother animal.

http://blog.cleveland.com/metro/2009/02/city_side_wholesale_car_dealer.html

For the ML possibility