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#2049308 - 11/12/15 04:43 PM CTR-Bus. customer exchanging cash for its client
2manyrules Offline
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Michigan
Let me preface this by stating we have vetted the circumstances around this transaction and it is NOT considered suspicious.

A cash-intensive business customer wants to order over $10,000 in cash (in a specific denomination) for one of its clients. They normally don't make these kinds of requests so when asked why, they said they are basically making change for their client, to be used in the business. The client will be paying the business in cash.

Would their client be considered a beneficiary on the CTR, or is this just normal cash for operating the business?

And doesn't the business have to file a form 8300 in this type of scenario? If so, does that mean we wouldn't need to include the client on our CTR, because that would/should be taken care of on the form 8300 the business is supposed to be filing?

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#2049333 - 11/12/15 05:43 PM Re: CTR-Bus. customer exchanging cash for its client 2manyrules
PrimeTime Offline
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The beneficiary on the transaction is the individual(s) that you're able to observe receiving the cash from the transaction; any story or details that they may provide you regarding where the money is going after the transaction is completed would be irrelevant for the purposes of the CTR. Your business customer would be the beneficiary of the transaction, as they are the ones who are receiving the cash, you would not include their client.

The filing of the 8300 would be the business' responsibility to file, so I don't think that should cause you too much concern.
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#2049344 - 11/12/15 06:16 PM Re: CTR-Bus. customer exchanging cash for its client 2manyrules
Elwood P. Dowd Offline
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As suggested, your customer told you a story. That does not affect how you complete the CTR.

Nor will it affect the way a third party, regulator or auditor, evaluates whether or not your bank should have filed a SAR based on the fact that the activity is apparently inconsistent with your customer's business, particularly if the "specific denomination" is $100 bills.
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#2049366 - 11/12/15 07:05 PM Re: CTR-Bus. customer exchanging cash for its client 2manyrules
rlcarey Online
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Galveston, TX
Vetted the circumstances? Yeah - right. What legitimate business or individual goes to someone other than a bank to exchange over $10,000 in cash for different specific denominations??? I would like to know the answer to that riddle.
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#2049368 - 11/12/15 07:09 PM Re: CTR-Bus. customer exchanging cash for its client 2manyrules
Elwood P. Dowd Offline
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Elwood P. Dowd
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Word to the wise: If Mr. Carey is your auditor, you're toast. wink
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#2049416 - 11/12/15 08:47 PM Re: CTR-Bus. customer exchanging cash for its client 2manyrules
2manyrules Offline
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Joined: Oct 2012
Posts: 12
Michigan
I wanted everyone to focus on the CTR aspect of the transaction rather than the SAR aspect...Believe me, I have the SAR aspect under control!!

They aren't exchanging small bills for bigger bills...just the opposite. For use within the business...

I'm sure you can read between the lines...or should I say poles? The client is apparently a celebrity and it is rumored that they want to visit their establishment, so the business owner wants to be sure he has enough change for this client if that should happen.

Anyway, we are looking into why/how the account was opened in the first place and are monitoring very closely.

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