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#2055339 - 12/22/15 05:42 PM CTR Question
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
We have an assistant who withdrawals over $10M in cash for their boss. I have question on how to complete question 22 on the CTR. We list the amount out on 22 for the beneficiary of the withdrawal, but would any amount need to be listed on question 22 for the conductor?
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#2055340 - 12/22/15 05:50 PM Re: CTR Question ACBbank
MyOhMyWeComply Offline
100 Club
Joined: Sep 2015
Posts: 115
Texas
Yes, they are the ones walking out with the funds.

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#2055358 - 12/22/15 06:39 PM Re: CTR Question ACBbank
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
I agree with MyOhMy. You would need to complete two Part I's. One for the assistant with box 2b (person conducting transaction for another) checked, and one for the boss with box 2c (person on whose behalf transaction was conducted) checked.
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#2055845 - 12/28/15 07:08 PM Re: CTR Question ACBbank
RYK190 Offline
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Joined: Oct 2015
Posts: 22
You'd need to list both the conductor AND beneficiary of the funds.

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#2057250 - 01/07/16 08:43 PM Re: CTR Question ACBbank
Little Miss BSA Offline
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Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
Think of it as each page tells the story of the transaction - You have the conductor page showing she transacted over $10k and a beneficiary or on behalf of page showing he/she benefited from a cash transaction over $10k.
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