Hey everyone! It's been a while since I've been on here & I need some thoughts.

When I was a BSA Officer - our bank contracted with Loomis. Loomis would go to our customer, pick up cash & then bring cash directly to their vault. Loomis would then send us the tickets to process. No cash ever came to our institution.

When we completed the CTR, we just checked the box that said Armored Car (FI Contract).

FinCEN just sent some weird instructions to a colleague & I can't make sense of it. Help?

You will treat this scenario as if the cash vault is another branch. Create a Part 3 for the off-site cash vault. Since it is not part of your institution, you can mark Other, type in the name of the Cash Vault, Mark IRS for Federal Regulator.

Has anyone ever heard this? & where is the instructions this is supposed to be completed this way?

I've also reached out to FinCEN myself directly & will update this post if they get back to me - but wanted to make sure I'm not insane for thinking these instructions don't make sense.

FYI - FinCEN is directing everyone to the latest CTR XML document. https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf. Pg 94.

NOTE: If the information entered into Part IV is the same for Part III check the box and complete Parts I
and II. Each FinCEN CTR filed may have up to 999 Part III’s.
Prepare a separate Part III section for each transaction location involved in the currency transaction(s). Include
the amount transacted at each Part III location in Item 41 “Cash-in amount for transaction location” and/or
Item 42 “Cash-out amount for transaction location.” A transaction location (such as an office or ATM, for
example) may be owned or operated by the reporting financial institution required to file the FinCEN CTR or
by another financial institution involved in the transaction(s) through a shared branching or other contractual
agreement.
Critical fields, denoted by an asterisk (*) in front of the item number, must be completed by providing the data
associated with that item. All other items must be completed when data are known but will be left blank when
data are unknown or do not apply.


I have auditors saying that if there is an ATM withdrawal done at Home Depot, we have to also include that as a location & fill in a Part III. Soooooo - do I now have to know what bank handles that ATM?

It may or may not be a bank as many ATMs are privately owned, but yes. If you can't tell from your ATM processor's records, then these links are also helpful.

VISA ATM Locator

Mastercard ATM Locator

So the answer is ... we ARE supposed to fill out a Part III for the Loomis/Home Depots (example) of the world???? Did I miss a webinar or does anyone have something that goes over this change?

I can understand Shared Branching transactions - or an ATM at an actual Financial Institution ....