Thread Options
#2246816 - 12/22/20 02:47 PM 3rd Party Cash Deposit and CTR Aggregation
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
I'm looking for how other banks handle the CTR aggregation requirement on accounts where a 3rd party person not affiliated with the account deposits cash into the account. I know some banks don't allow 3rd parties to deposit cash into an account their not a signor on. I'l looking to see how the banks that do allow 3rd party cash deposits handle the aggregation requirement.

Return to Top
BSA/AML/CIP/OFAC Forum
#2246826 - 12/22/20 04:35 PM Re: 3rd Party Cash Deposit and CTR Aggregation jhoch
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,408
Cape Cod
Banks complete cash deposits conducted by third-party non-signers all the time. Consider how many of your business customers send an employee who doesn't sign on the customer account with their daily deposit. But regardless of what your policy on that question is, if it happens, here's what the CTR should look like:

If the bank knows that a CTR is required when the third party makes the deposit (e.g., the deposit includes more than $10,000 in cash or a system prompt on the teller terminal notifying that the cash amount in the current deposit takes the aggregate cash-in amounts over $10,000 on the current business day), the bank will need to obtain personal info from the third-party to complete a Part I entry for them as a conductor.

If the bank is not aware of the fact that the deposit will make a CTR necessary when the transaction is completed (typically they learn the CTR is needed the next day when cash aggregation reports provide that information), and the bank is not aware of any conductor names, it will check the "aggregated transactions excuse box" in item 24 of Part II to indicate that at least one of the transactions was processed by a teller, and that none of the transactions included a reportable cash amount by itself. And there will not be a Part I entry for a conductor.

Note, though, that if the bank does know one conductor of the deposits included on the CTR, that conductor will be reported in a Part I section (box 2a checked), and the aggregated transactions box in Part II should NOT be checked.
Last edited by John Burnett; 12/23/20 03:20 PM. Reason: additional info
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2246978 - 12/29/20 01:31 PM Re: 3rd Party Cash Deposit and CTR Aggregation John Burnett
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
Thank you for your response. Understood on aggregating at the account level but how about at the conductor level. If the third party individual deposits $5,000 into Company XYZ in the morning, and $4,000 into Company ABC at noon at a separate branch (not a signor on either account) and then $2,000 into his/her personal account in the afternoon at another branch then would the bank be REQUIRED to file the aggregated CTR on that person even if it didn't know who deposited the cash into XYZ and ABC?

Return to Top
#2246981 - 12/29/20 02:48 PM Re: 3rd Party Cash Deposit and CTR Aggregation jhoch
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,598
Galveston, TX
You file on what you know If you have no method to track such cash deposits by conductors, then you do not know what you do not know.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z