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#571304 - 06/21/06 05:54 PM WHO on the CTR?
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
Two people walk into the bank with a cashiers check payable to a business for $14,900. The check is deposited into the business checking account. Person A is an authorized signer on the business account. Person B is not. Person A makes an immediate debit to the account for $14,900. The teller counts out the cash to Person B. Person B walks out with the cash. How do I complete the CTR?

I say just Person B, but I think I am trying to talk myself out of it. Please advise and thanks!

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#571305 - 06/21/06 06:29 PM Re: WHO on the CTR?
hawkfan Offline
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Joined: Feb 2006
Posts: 83
Why did the teller count the cash to Person B, if they are not on the account?

I would say if you did not know this was taken out for the business, you would put both A and B (also because you do know who it really benefits). So Section A on both of customers, and check the box conducted on own behalf.

IMO, without further information, that is what I would do.

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#571306 - 06/21/06 06:30 PM Re: WHO on the CTR?
Big Dog Offline
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Unless you saw them split the loot, then I would only report Person A, since that is who performed the transaction.
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#571307 - 06/21/06 07:20 PM Re: WHO on the CTR?
hawkfan Offline
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Joined: Feb 2006
Posts: 83
Why would you report only person A if it was B who walked out with the cash?

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#571308 - 06/21/06 07:36 PM Re: WHO on the CTR?
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
Teller counted to Person B upon instruction from Person A. Both people were standing there at the same time. No one saw them split the loot, but we do know the two people are former business partners.

What if it's like writing a check, but Person A didn't have any checks on him, so that he could write a check to Person B to cash?

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#571309 - 06/21/06 07:54 PM Re: WHO on the CTR?
nemsi Offline
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Joined: Nov 2005
Posts: 383
Since Person A is authorized signer and person B is not- I assume the debit was an internal document- person A would have to conduct the transaction. Not sure why it would have been counted back to Person B but since it was I would complete a Section A on each person. The whole thing seems suspicious so I would want to identify both individuals and monitor future transactions. If there is reason to believe that the transaction was done on behalf of the entity, I would complete a Section B on each person.
May not be right but that's what I would do.

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#571310 - 06/21/06 08:11 PM Re: WHO on the CTR?
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
Thanks everyone. Think I'll go with both people in section A.

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#571311 - 06/21/06 08:50 PM Re: WHO on the CTR?
Big Dog Offline
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Sorry, I missed the "counted out to person B" part.

{Bad Dog - Go lay down!}
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#571312 - 06/22/06 05:52 PM Re: WHO on the CTR?
Tiger Fan Offline
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Joined: Jun 2002
Posts: 180
I have a similar situation. Our customer (Person A) is a sole proprietorship. Check in excess of $10,000 was made payable to a non-customer(Person B). Person B is a non-resident alien, so both Person A and B came to the bank to cash the check both signed the back of the check. The money was given to Person B. Earlier in the day, Person A cashed a check for less than $10,000. (Are you with me so far??) Now, do I list both Person A and B in Section A and show the amount of the cash out as the total of the two checks? Or do I show Person B only in section A for the one check?

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#571313 - 06/22/06 06:11 PM Re: WHO on the CTR?
nemsi Offline
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Joined: Nov 2005
Posts: 383
Did your customer "A" simply endorse as a means of id'ing person "b". If so, I would probably complete with person "b" section A (for benefit of)- conducted on own behalf.

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