Skip to content
GeoDataVision
Thread Options
#2191845 - 09/06/18 06:42 PM CTR Withdrawal Joint Account
Nick Offline
New Poster
Joined: Mar 2017
Posts: 20
Hello,

We have always included joint account holders when doing a CTR for cash withdrawals. With that being said, If a one account holders (person A) comes in and withdrawals $20,000 and then during the same day the other account holder (person B) comes in and withdrawals $100 cash out of an account that only has his name on it, would that cash withdrawal by person B be included on the CTR? If going by my initial thought I was going to file the CTR as:

Part I: Person A, Conducting transaction on own behalf - $20,000
Part I: Person B, Conducting transaction on own behalf- $20,100

Does that work?

Return to Top
BSA/AML/CIP/OFAC Forum
#2191846 - 09/06/18 06:52 PM Re: CTR Withdrawal Joint Account Nick
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,246
If I were including a joint owner on the CTR for withdrawals, I'd file it as you indicated in this scenario.
_________________________
CRCM, CAMS

Return to Top
#2191880 - 09/06/18 09:51 PM Re: CTR Withdrawal Joint Account Nick
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
If you are assuming that Person B benefitted from the $20,000 withdrawn by Person A, why do you not make the same assumption about Person A benefitting from the $100 withdrawn by Person B.

FAQ #24 put out by FinCEN is pretty specific about only including joint owners on withdrawals if the institution HAS knowledge that the individual not present will benefit from the transaction.

I would re-examine why joint owners are being included on the CTR in the first place.
Last edited by TXBSA; 09/06/18 10:01 PM.
Return to Top
#2191888 - 09/06/18 11:25 PM Re: CTR Withdrawal Joint Account Nick
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,322
Illinois
I almost posted the same, but look at the OP carefully. The $100 withdrawal was from an individual account.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2191926 - 09/07/18 04:00 PM Re: CTR Withdrawal Joint Account Nick
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
I back what TXBSA said. I would not include the joint owner simply because they are a joint owner. Our front line staff are trained and hopefully ask questions to determine how the money will be used. If Person A takes 20,000 and goes on a weekend retreat that Person B does not get to go on it seems that there is no reason for Person B to be on a CTR.

BrianC great observation per usual. I missed it after first read.

Return to Top
#2191957 - 09/07/18 07:15 PM Re: CTR Withdrawal Joint Account Nick
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
I missed that as well. Sorry about that! If you are going to include the joint owner then your original thought would be correct.

Return to Top
#2191976 - 09/07/18 08:34 PM Re: CTR Withdrawal Joint Account Nick
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,697
Cape Cod
Originally Posted By LiveFunLife
If Person A takes 20,000 and goes on a weekend retreat
Definitely living the fun life! One heck of a retreat.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z