A business account owner directs its clients (renters of 300+ real estate properties) to make their payments directly to our branches.
We have two issues:
1). We typically permit non-customers to make deposits to accounts, but we do not truly have the capacity to accept this many transactions at our locations each month.
2). These deposits are cash, and are triggering CTR requirements for individuals we do not have the proper information for those who have already transacted and left.

We are considering telling the business holder that we cannot continue to administer his accounts in the capacity for the above reasons - are there any concerns of unfair treatment, since we do typically accept non-customer deposits on our other accounts?

I'm not aware of a bank (outside of a formal lockbox agreement) that would accept payments in this manner for a customer - especially cash.

Amen to what Randy said. This could also possibly be smurfing which is a method to wash illicit funds.

We are considering telling the business holder that we cannot continue to administer his accounts in the capacity for the above reasons - are there any concerns of unfair treatment, since we do typically accept non-customer deposits on our other accounts?


They are most likely doing this as to avoid lockbox charges at other institutions (or possibly yours). You have every right to enforce policy that prohibits this.

"These deposits are cash, and are triggering CTR requirements for individuals we do not have the proper information for those who have already transacted and left." I do not even know how they would determine who has paid their rent or not (if it is a legit account and not a BSA nightmare)

This thing is like an onion - there are so many layers my gut says there could be something even darker at play. Can't act on guts alone, unfortunately, but I am about to make it as inconvenient as possible!
Thanks for the input!

You remember when Jack Ryan was trying to figure out how Captain Ramius was going to get the crew off the Red October? Make them want to get off?

You didn't mention fees. Figure out what it would cost to create a record for each person making a cash payment that would flow into your CTR system. Require their identification, record it, and ask to see it every time a payment is made. (In other words, do this right.) Then add a nice profit margin for the bank.

He'll get off the boat.