Two back-office employees were conducting a safe deposit box break-open in which cash >$10,000 was found. A third employee, the Branch Manager, was called in to double-count the cash and notarize the document listing the contents. We listed all three as conducting on the CTR - is this correct?

My guess is nope.

a. the funds should stay as is and locked dual control until escheated to the state or other state law possibility.
b. if a check is issued it would be for bank use hence no ctr..
C. the notary should not be part of the process (should not have counted)


I would wait for someone else to chime in though

It's been awhile since I was in a BSA capacity, but I agree with Ed. I don't think a CTR is involved at all. CTR is for tracking currency coming in and out of the institution through accounts and/or exchanges. The money has already entered the building, I just don't see a CTR being appropriate in this situation.

But as I said, I am out of the BSA world these days. I think I would probably be calling FinCEN on this particular issue and get their guidance.

The funds never went into or out of a customer account. There is no CTR to file. As previously mentioned, the funds should be considered part of the contents of the box and nothing further.

^^^ This.

Agree with the "no CTR" crowd- you are not transacting with the funds. You are simply placing them in the appropriate storage in their current form until they become subject to escheat.

If you did transact and park the funds in a GL or bank-controlled account, then I would suggest that you revisit your delinquent box drilling procedures.

You'll find discussion of a couple of similar scenarios in this prior thread.