We have a CTR where we are filing 2 part 1 because of it being a joint account. For the second person, we are marking Person on whose behalf transaction was conducted, but can we mark unknown for identification? It prior audits, it was always listed as an exception because they are are customer and we should have it. The account was opened prior to CIP rules and we don't have the persons ID. We did list the ID for the person who actually made the deposit.

From a CTR perspective, we are only required to obtain identification from the individual(s) who bring in or take out the cash. If we have additional information in our possession for joint owners, then include it on the CTR. If we are missing certain information such as identification, then checking unknown is perfectly acceptable. I would debate with any auditor or examiner that cites checking unknown as a finding on this CTR.

Thanks Brian! That is what I thought, if we have it then we need to list it. We have everything needed on the actual person bringing in the cash.

Always the gentleman. I'd just give them a head slap and say, "What's the matter with you?"

I realize this is an old thread, but I'm looking for the guidance that indicates that we are only "required" to get the information for the conductor of the transaction.

We have a recent incident - customers for 40+ years. One owner typically conducts the transactions and we have that individual's completed information. The spouse (joint owner) there are missing pieces of info (DL number, etc.).
A teller wanted to refuse the deposit into the joint account because the joint owner (who was not present) had incomplete information.

I've searched FinCEN.gov and threads here, but I just can't put my finger on the guidance or instructions that might ease the teller's concerns.

This is in the CTR FAQ's and does not mention that we have to have the Joint owner's information. Just put unknown as mentioned above.

23. How do I properly complete Part I on the FinCEN CTR for deposits into a joint account? What amounts do we show in Item 21 for each Part I? For example, John and Jane Smith have a joint account together. John Smith deposited $5,000 into the…




How do I properly complete Part I on the FinCEN CTR for deposits into a joint account? What amounts do we show in Item 21 for each Part I? For example, John and Jane Smith have a joint account together. John Smith deposited $5,000 into the account; later in the same business day, Jane Smith deposited $7,000 into the account.

When a deposit is made into a joint account, the deposit is presumed to be made on the behalf of all account holders because all account holders have potential access to the account balance, and multiple Part Is are required. In this example, the financial institution would complete four Part Is, two for John Smith and two for Jane Smith since each person has more than one Item 2 role.

One of the Part Is for John Smith would be completed by checking 2a "Person conducting transaction on own behalf" and entering $5,000 into Item 21 and the account number of the joint account. The other Part I for John Smith would be completed by checking 2c "Person on whose behalf transaction was conducted" and entering $7,000 into Item 21 and the account number of the joint account. One of the Part Is for Jane Smith would be completed by checking 2a "Person conducting transaction on own behalf" and entering $7,000 into Item 21 and the account number of the joint account. The other Part I for Jane would be completed by checking 2c "Person on whose behalf transaction was conducted" and entering $5,000 into Item 21 and the account number of the joint account.

Note: If Jane Smith did not conduct a deposit, but John Smith deposited $12,000 into the joint account, there would only be two Part Is. One Part I would be for John Smith as 2a "Person conducting transaction on own behalf" and entering $12,000 in Item 21 and the account number affected. The other Part I would be for Jane smith, checking 2c "Person on whose behalf transaction was conducted," entering $12,000 in Item 21, and providing the account number affected.