Skip to content
BOL Conferences
Thread Options
#2126644 - 04/18/17 10:48 AM CTR required ?
LC Northeast Offline
New Poster
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?

Return to Top
BSA/AML/CIP/OFAC Forum
#2126645 - 04/18/17 11:12 AM Re: CTR required ? LC Northeast
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
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?
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2126646 - 04/18/17 11:14 AM Re: CTR required ? LC Northeast
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
The again why would it be several checks?

SAR investigation?
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2126651 - 04/18/17 12:15 PM Re: CTR required ? LC Northeast
LC Northeast Offline
New Poster
Joined: Feb 2017
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.
Return to Top
#2126653 - 04/18/17 12:20 PM Re: CTR required ? LC Northeast
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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.)
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2126672 - 04/18/17 01:52 PM Re: CTR required ? LC Northeast
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
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.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z