I will admit I am new at filing CTRs, so this baffles me. I hope someone has had this situation.

A construction worker (not our customer) comes into the bank and cashed an on-us $9,900 check from his employer, he later the same day cashed another on-us $9,900 check from his employer. He is not our customer, and besides the DL number written on the check that was cashed, I have no information on him.

I don't know his address or anything. Do I contact the construction company (his employer and our customer) and ask them for his information? What is the proper thing to do?

You should take reasonable steps to obtain the missing information. We would typically contact the employer and ask for contact information. Obviously care should be taken not to breach the customer's privacy during the conversation with the employer.

Sometimes you are able to utilize various search engines to obtain some of the info (such as an address) when you have a full name and general location. Be creative. We had one CTR to file and the teller had obtained most of the info we needed, but neglected to document the individual's occupation. After several unsuccessful attempts to contact the employer and the individual, we went to "Plan B". We suspected that he was contractor that handled home improvements. I found his telephone number on searchbug.com and called his home to see if he was a contractor. He was.

The next step is to look closely at the checks (consecutive numbers, dates, etc.) to determine whether you have a structuring situation that may warrant a SAR. A brief glance suggests that perhaps the employer worked together with this individual to structure.

Thanks BrendaC. This guy gets paid weekly, so the tellers told me he will probably be back in the bank at the end of this week. So I think we may try to get a copy of his ID then, or I might try to research on the Internet like you did. I went back and reviewed everything we have and we are only missing his address. So my situation is not as bad as I thought.

I thought about the structuring as well. I'm looking into it.

Thanks Again!!

LauraL, You might also want to place the individual and your customer on your "watch list" given the amount of the checks (9,900) and the fact that he cashed the 2 checks separately.

BrendaC, I'm trying to think what privacy issue might come up since the guy cashing the checks isn't a customer of the bank. The employer you are contacting is the customer. We have also used this option to obtain information.

Good idea DevsFan. I will do that.

Thanks!

Locking the barn door, but... our procedures require tellers to document the identification on checks cashed by non-customers and complete a "High Dollar" ticket for cash transactions exceeding $3,000, with required CTR information in case of aggregate reporting.

Even if the individual is not a "customer" as defined by GLBA, we like to be sensitive to reputational risk and legal risk when dealing with these type situations. We are in a very litigious state and attorneys don't come cheap. Sometimes even if you win, you lose. Just erring on the side of safety!

I found this thread while researching an answer to a situation I have. We have a situation almost identical to this except for the check amount. We have everything we need except the social security number. We will be looking at filing a SAR, but how do I go about filing the CTR? Any suggestions?