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#2267784 - 03/16/22 07:44 PM CTR for Exchange of Cash
JacksTigger Offline
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JacksTigger
Joined: Jan 2010
Posts: 265
lost in compliance land
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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#2267785 - 03/16/22 07:57 PM Re: CTR for Exchange of Cash JacksTigger
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
A customer comes in and buys a cashier's check with cash - why would that scenario alone trigger a SAR without additional information that makes the transaction suspicious? Also, I am not sure why Joe would go on the CTR.
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#2267786 - 03/16/22 08:07 PM Re: CTR for Exchange of Cash JacksTigger
JacksTigger Offline
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JacksTigger
Joined: Jan 2010
Posts: 265
lost in compliance land
Based on the conversation Jane had with the branch staff, we are have determined this is not your usual just purchasing a cashier's check for cash but is something much more. Like I said we want to be able to show to auditors and examiners that the two reports are connected. From what we understand Joe is a friend of a friend....Since the check was made out to Joe he is really benefitting from the transaction, not Jane.
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#2267790 - 03/16/22 08:18 PM Re: CTR for Exchange of Cash JacksTigger
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
There is no beneficiary information shown on a CTR. If Jane was conducting the transaction on behalf of Joe - then all of Joe's information had to be obtained at the time of the transaction. If that is what happened, then your time to gather that information is long past if they will not cooperate. But if she first deposited the money into her account, then I am not sure how that could be true as the money was hers at that point. If there are other contributing factors for the SAR, that is where that information belongs and not on a CTR..
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#2267791 - 03/16/22 08:34 PM Re: CTR for Exchange of Cash JacksTigger
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,700
The Country
I echo the sentiment that while Joe would be part of the SAR if you are filing one, but should not be included in the CTR.
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#2267798 - 03/16/22 09:08 PM Re: CTR for Exchange of Cash JacksTigger
ColoradoAML Offline
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Joined: Mar 2018
Posts: 338
I agree with rlcarey and RockChucker about the CTR, but with the clarification that "a check for Joe" means a check payable to Joe. If Jane used this cash to purchase a check on behalf of Joe (Joe is the remitter) instead of to Joe, then my opinion is Joe needs to be listed on the CTR.
Last edited by ColoradoAML; 03/16/22 09:09 PM.
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