I found out that one of our known, frequent conductors listed on CTRs changed his address. Since that time, each subsequent CTR we have filed has omitted his apartment number. For instance, we have reported his address as 12345 Addams Lane, Transylvania, PA, but we should have been reporting 12345 Addams Lane, Apt 23, Transylvania PA.

Would you fix this just on a going-forward basis, or would you consider filing corrections on all the prior CTRs?

My initial assessment is that 12345 Addams is in fact accurate; that is his street address and he can be found there. If someone hypothetically actually needed to find him they might have to call us for an apartment number or ask the landlord, but we haven't been providing incorrect info, just not perfectly complete info.

I'm inclined to fix it on a going-forward basis. The alternative is to look at 2 years of voluntary backfiling on perhaps 100 or more CTRs. I feel that this backfiling would add basically no value to the database of data available to law enforcement.

OP here: Here is a reference from FinCEN: "Provide the apartment number or suite number, if known, following the street address"

That to me implies they wouldn't consider the apartment number enough of an issue to warrant backfiling or filing hundreds of corrections.

Also, I think that based on how this issue was discovered, the information was not "known" until it was discovered, therefore, we fix it going forward. We detected the issue by DuckDuckGo'ing his address (doesn't roll off the tongue quite like "Googling" does it?) and detecting that the address corresponded to an apartment building.

We consider an apartment or suite number to be part of the address, and we would generally consider this to be something that would require an amendment. I understand your argument that FinCEN may have given you an out by including "if known," but I'd be concerned that an examiner would argue that if you discover that information you file in a CTR or SAR was not accurate, you now do have knowledge and should fix the filing through an amendment.

For instance, if we didn't have key information about the identity of a conductor - for instance a non-customer who cashed a check - and were forced to file an incomplete CTR based on what we knew, but later learned the information we'd omitted, we would amend the CTR to be accurate.

My real recommendation is to call FinCEN, explain the situation and make it clear that everything is accurate except the apartment number, and be sure to tell them how many CTRs you'll need to amend, and what you've done to make sure it's accurate going forward. Past experience isn't a guarantee of future performance and all, but in my experience they will generally give you permission not to amend the reports. Document whatever they tell you and hand it to your regulator when they show up.

Devil's Advocate:

Why did it take two years to discover that your CTR conductor changed his address? Is your staff not asking for an ID when there is a reportable transaction?

Not trying to be an a$$ by asking the question; just curious.

Depending where people live and if they rent or own, moving every year and not updating your license is normal. When I lived in Manhattan my current DL was 3 or 4 addresses behind my current address.

Moving every year is normal?

Regardless, asking for an ID creates a conversation: is your information current?

and they say "yes"...

If you rent and live in a city, you could move every year, maybe two. I know many people who were never in the same building for more than a year or two due to a rent increase or wanting to experience a different part of the city.

... or different neighbors.