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#2126644 - 04/18/17 10:48 AM CTR required ?
LC Northeast Offline
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Joined: Feb 2017
Posts: 18
Scenario - Mr. Customer visits bank with cash and purchases several checks payable to an exempt customer exceeding the CTR limit.
CTR required? I'm leaning towards yes as Mr. Customer is not exempt and he is the one who brought in the cash.
Thoughts?

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#2126645 - 04/18/17 11:12 AM Re: CTR required ? LC Northeast
edAudit Offline
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edAudit
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Yes Mr. Customer is not exempt and he is the one who brought in the cash

Mr. Customer is not a messenger for the exempt?
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#2126646 - 04/18/17 11:14 AM Re: CTR required ? LC Northeast
edAudit Offline
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edAudit
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The again why would it be several checks?

SAR investigation?
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#2126651 - 04/18/17 12:15 PM Re: CTR required ? LC Northeast
LC Northeast Offline
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Posts: 18
Does it matter if its a Phase1 or a Phase2 Exempt customer?
Last edited by LC Northeast; 04/18/17 12:15 PM.
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#2126653 - 04/18/17 12:20 PM Re: CTR required ? LC Northeast
Elwood P. Dowd Offline
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Elwood P. Dowd
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Phase I customers are exempt for all large currency transactions. Phase II customers are only exempt for deposits and withdrawals.

That's irrelevant here because the individual, not the customer, was the purchaser. (The customer was the payee on the checks, not the remitter.)
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#2126672 - 04/18/17 01:52 PM Re: CTR required ? LC Northeast
John Burnett Offline
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John Burnett
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Cape Cod
Just to put an unrequested bow on this, if the scenario were a bit different and the remitter were an exempt government agency, and the total of the purchase transaction were $9,500, don't get confused and forget to make your cash purchases of monetary instruments recordkeeping entry. There are no exemptions from that requirement, and the purchaser in such a case would be the individual making the purchase, not the remitter.
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