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#2245764 - 11/20/20 09:38 PM CTR filing
Bjet Offline
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Joined: Sep 2012
Posts: 40
I have a CTR that needs to be filed, can you help with how this CTR should be reported?

Customer has a Corporate business account which husband and wife are signers on with our financial institution. The wife writes a check payable to her husband off of the Corporate business account with us in the amount of $18,000. The wife brings the check payable to her husband off of the Corporate business account at our financial institution to be cashed. The check she presented to our teller was payable to her husband and was already endorsed by her husband so the teller had her endorse the check as well since she was the one taking the cash. Would we only need to report on the wife since she is the one that took the cash?

Thank you.

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#2245766 - 11/21/20 12:06 AM Re: CTR filing Bjet
ColoradoAML Offline
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Joined: Mar 2018
Posts: 289
I'd indicate that both benefit from the transaction.

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#2245803 - 11/23/20 10:59 PM Re: CTR filing ColoradoAML
Bjet Offline
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Joined: Sep 2012
Posts: 40
So on Part I would you list the wife as 2a person conducting transaction on own behalf and for the husband list 2b person on whose behalf transaction was conducted??

Let me know.

Thanks!!

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#2245816 - 11/24/20 03:00 PM Re: CTR filing Bjet
ColoradoAML Offline
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Joined: Mar 2018
Posts: 289
Yes, that's exactly how I'd complete it.

For what it's worth, I think if you were to complete this as wife for her own benefit or wife for someone else because you (or your teller) understood the transaction that way, I think you'd still be right in both cases. Without that clear understanding, I think this is the most readily justifiable way to complete it without having to over think it.

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#2245817 - 11/24/20 03:16 PM Re: CTR filing ColoradoAML
Bjet Offline
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Joined: Sep 2012
Posts: 40
Thank you so much, appreciate your help!!

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#2245852 - 11/24/20 09:43 PM Re: CTR filing Bjet
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Wife - 2a
Husband - 2c
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2245853 - 11/24/20 09:45 PM Re: CTR filing Bjet
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Unless you know that the check cashing was done on behalf of the business. That's a possibility, after all. In that case, Wife would be 2b and the business would be 2c.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2245859 - 11/24/20 10:34 PM Re: CTR filing John Burnett
Bjet Offline
Junior Member
Joined: Sep 2012
Posts: 40
Thank you.

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#2245874 - 11/25/20 03:20 PM Re: CTR filing Bjet
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Originally Posted by Bjet
I have a CTR that needs to be filed, can you help with how this CTR should be reported?

Customer has a Corporate business account which husband and wife are signers on with our financial institution. The wife writes a check payable to her husband off of the Corporate business account with us in the amount of $18,000. The wife brings the check payable to her husband off of the Corporate business account at our financial institution to be cashed. The check she presented to our teller was payable to her husband and was already endorsed by her husband so the teller had her endorse the check as well since she was the one taking the cash. Would we only need to report on the wife since she is the one that took the cash?

Thank you.


The problem with your scenario is that nowhere does it say that anyone at the bank ASKED the conductor the purpose of the transaction. The one thing we know is the wife was the conductor, but we don't know whether she completed the transaction (a) on her own behalf, (b) on her own behalf and on behalf of her husband, (c) on behalf of her husband only, (d) on behalf of the corporation, or (e) on behalf of some other combination of players in this drama. That leaves the bank in the position of having to make some presumptions, when a well-trained teller may have been able to determine the purpose of the transaction with a simple question.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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