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#2242981 - 09/23/20 03:49 PM CTR Completion for Amish Customer
Complycated Offline
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Posts: 149
In the past, I attended seminars led by Ken Golliher in which he advised us that if a CTR was filed on an Amish customer we were to put "Amish" in the Identification field for the individual. There is also an old article on this site (www.bankersonline.com/articles/109313) that says the same thing. Have there been any updates to this or is it still valid guidance?

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#2242982 - 09/23/20 04:12 PM Re: CTR Completion for Amish Customer Complycated
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,074
Illinois
These instructions apply to the legacy FinCEN CTR 104 in the references to Section A & B.

For the current electronic form, there are a some critical fields where you will be checking the 'unknown' box (e.g. Tax ID number.) For the identification field, selecting "Other" and entering "Amish Customer" would be the logical derivation from these legacy instructions.

As noted in the article, your CIP, CTR and SAR procedures should cover these groups if you are providing services to them.
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#2242984 - 09/23/20 04:17 PM Re: CTR Completion for Amish Customer Complycated
John Burnett Offline
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John Burnett
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Cape Cod
Since 2003, banks have been required to obtain an SSN for U.S. persons opening an account. I've been told that the Amish do, in fact, have Social Security numbers because they need them to pay income taxes (and now, to open a bank account), they just don't participate in the Social Security system.
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BankersOnline.com
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#2242995 - 09/23/20 06:09 PM Re: CTR Completion for Amish Customer Complycated
Complycated Offline
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The customers in question have social security numbers on file, we just don't have any traditional identification like a drivers license for them to enter in item 20.

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#2243014 - 09/24/20 01:04 AM Re: CTR Completion for Amish Customer Complycated
Patriot Offline
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Joined: Apr 2016
Posts: 26
We also list identification as Amish customer. All our Amish customers have social security numbers.
We have never been questioned by examiners.

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#2243027 - 09/24/20 02:18 PM Re: CTR Completion for Amish Customer Complycated
John Burnett Offline
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John Burnett
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Cape Cod
Of course, as with most religious groups, there are those people who may in fact have a state-issued ID or driver's license. You can't assume.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2243031 - 09/24/20 03:20 PM Re: CTR Completion for Amish Customer Complycated
Complycated Offline
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Joined: Aug 2013
Posts: 149
We've never been questioned on this either until a recent BSA audit. We used a firm we've never worked with before and have had a lot of "interesting" things come up.

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