Need help with a CTR. Jane deposited $15,000 into her account. Jane then asks branch staff to withdraw $15,000 as a check made out to Joe. From talking to branch staff, I realized that Jane just wanted to exchange the cash for a check for Joe. I have all the information I need for a CTR to identify Jane, but all I have for Joe is his name--not a customer. This whole scenario will also most likely end up in a SAR, so I want to to be able to show the connection between the two reports. Would you do a Part 1 for Joe to show his part in the transaction even though I only have a name? Have you been sited for not having all of Joe's info?
thanks
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CRCM