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#2111693 - 12/21/16 03:35 PM CTR- Bank Withdrawal
TXBSA Offline
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Joined: May 2006
Posts: 170
TX
We had an employee withdraw a CTR reportable amount of cash from an internal GL account to give out as employee bonuses. Is this transaction CTR reportable?

My first reaction is no because the transaction was on behalf of the bank.

Thanks!

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#2111699 - 12/21/16 04:42 PM Re: CTR- Bank Withdrawal TXBSA
SeekingKnowledge Offline
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SeekingKnowledge
Joined: Jun 2014
Posts: 152
SC
I remember reading something similar to this a while back and managed to dig it up, you might find this thread useful...

Previous Thread

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#2111795 - 12/21/16 10:17 PM Re: CTR- Bank Withdrawal TXBSA
TXBSA Offline
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Joined: May 2006
Posts: 170
TX
Thank you for the Previous thread!

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#2111806 - 12/22/16 01:01 PM Re: CTR- Bank Withdrawal TXBSA
bcompliance Offline
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Joined: Sep 2014
Posts: 1,245
If I were you, I would be contacting FinCEN for an official interpretation, and document their response.
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CRCM, CAMS

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#2111815 - 12/22/16 01:38 PM Re: CTR- Bank Withdrawal bcompliance
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
Originally Posted By bcompliance
If I were you, I would be contacting FinCEN for an official interpretation, and document their response.


Why? It is no different than the head teller debiting the vault's G/L account and getting cash for delivery to one of the other tellers in the bank.

Just make sure these cash bonuses get into the employee's W-2s smile
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#2111839 - 12/22/16 02:29 PM Re: CTR- Bank Withdrawal TXBSA
bcompliance Offline
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Joined: Sep 2014
Posts: 1,245
I guess you could say I am a little paranoid smile
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