A business client requests to make a large cash withdrawal (>$100,000). We are able to verify the source of funds (sale of property) and when attempting to understand the purpose of the withdrawal and who is benefitting, we were advised that these monies are intended to pay back a loan given by a friend who wants cash due to divorce proceedings in place. In light of this knowledge, who should be listed as benefitting from the funds on the CTR? One can reason tagging the "friend" based on the information provided, however, one can reason tagging the conductor since he/she is actually receiving the funds.

I recommend "tagging" the conductor only. There's every possibility the conductor has trumped up a story to make the cash withdrawal seem legit. If the "friend" were there in person with him, I'd think differently. There would also be some chance of getting identifying information on the friend for the CTR if he were there.

Thank you, John!

Another way to look at it: The conductor is benefitting as the funds are being used to extinguish his debt. (If this is a true story.)