Bank A has a customer in need of $150,000.00 in cash. Bank A contact it correspondent for the cash (Bank B).

Bank B, not having significant cash on-hand contacts it correspondent (Bank C).

Customer sends an Armored Car to Bank C to pick up the cash and it is delivered to the customer.

Who files the CTR? My understanding would be Bank C, since they turned the cash over to the agent of the customer.

AM I correct?

Thank you,

BC78a

Phase I CTR Exemptions (31 CFR 1020.315(b)(1)-(5))

FinCEN’s rule identifies five categories of Phase I exempt persons:
•A bank, to the extent of its domestic operations.


http://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_019.htm

This is not a phase 1 exemption case, in the end, a non bank gets the cash (customer of Bank A gets the cash from Bank C)

Sorry miss the customer part.

I would say that you are correct in thinking that Bank C should be filing the CTR. They are the location which physically conducted the transaction, therefore they are responsible.

It is my understanding that Bank A should file the CTR for its customer. I would not rely on a correspondent bank to file unless you have an agreement with them that explicitly states they will do so.

Thank you all