If a customer withdraws over $10,000 in cash and during the conversation with the customer, the teller finds out he is taking the cash out of the country are we obligated to file a 4790 or is a 4789 sufficient? We only know this from something picked up in passing conversation.

IT depends on the circumstance. I think that I would file the form, even if I was only finding out through conversation. Conversations held with customers let you in on a great deal about their situations. It is one method of helping find out WHO your customer is and one method of assisting in monitoring the customer activity.

Now, there are exceptions listed on the back of the #4790 form. Perhaps your customer fits into the exceptions profile.

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The views expressed, herein, are not necessarily those of my employer

You should be doing the 4789 when the transaction occurs in your bank.

The customer would handle the 4790 when they take the cash out of the country. You'd be responsible if you actually did the shipping or handled it in some way.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

I'm with Andy. The 4790 is a U.S. Customs declaration form for travelers. Customers say all kinds of things, but the bank has no actual knowledge that the cash is exported or imported. The bank I worked for filed 50K CTRs per year but I can't recall a single time when we shipped or received currency to/from a foreign destination & were required to file a CMIR.