We have a large brazillian community here and lately there have been a number of individuals (who are non customers) cashing large checks. These individuals have passports but no tax id numbers. The transactions being conducted trigger ctr filing. I am aware that these ctr's will be returned, we are including a note with the ctr stating that the individuals do not have tax id number's. Has anyone else run into these situations? If so how does your institution handle them?
We generally do not cash checks for non-customers for the basic reason of paperwork nightmare - OFAC check, repeated follow up (you're supposed to re-check every 6 mos) the CTR would just compound the problem.
I am assuming that the check has been written by one of your customers, so you would have to cash it. Non US citizens are allowed in the country and are allowed to have accounts and cash checks. You don't have to have a Tax ID number - you have to have proper ID. If you provided the proper ID to the IRS I don't see why the CTR would be returned.