Jane Doe uses $12,000 cash to purchase two $6,000 cashier's checks payable to non-customers. Jane Doe will be classified as the conductor. Must I include payees' names on the CTR, since they ultimately benefit from the cashier's checks? I am unsure how I would classify their role in the CTR.

Hindsight being 20/20, I wish the teller would direct her to deposit the cash into her account and then write a check to purchase cashier's checks.

The payees have no role in the CTR.

Agreed, you don't need to include the payees of the cashier's checks.

Thanks all! I had a feeling I was reading too far into this.

Hello,
I have a possibly related situation. One of our customers came in and made over $10,000 deposit into his business accounts and also purchased a cashier's check on behalf of a non-customer. The cashier's check does not benefit our customer or the businesses. Do we file the CTR with the non-customer included as "account owner on behalf of" or just under the conductor?

You mean you listed a remitter on the cashier check that was purchased with cash that was not either present or you had no proof that they were someone authorized to conduct a transaction on their behalf?

I am not aware that banks allowed that to happen. It can lead to a lot of bad things.

Yeah, like being an unlicensed MSB.