Skip to content
GeoDataVision
Thread Options
#599515 - 08/15/06 06:17 PM Weird CTR but hopefully YOU have the answer!
Dip Offline
Power Poster
Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
An amount over $10,000 shows up for a customer (entity) on my large cash transaction report. I look it up and it is the result of the entity's employees coming in to cash payroll checks.

The entity neither conducted or benefitted from the transaction. 14 separate individuals conducted and benefitted from the multiple transactions. Singley, none of the transactions are reportable.

How in the world do I fill out the CTR???
_________________________
Dabbling in banking, law, accounting...the life of a trustee.

Return to Top
BSA/AML/CIP/OFAC Forum
#599516 - 08/15/06 06:21 PM Re: Weird CTR but hopefully YOU have the answer!
#12 Offline
Diamond Poster
Joined: Jun 2005
Posts: 1,338
You don't fill out a CTR in this case. No one person left with more than $10,000 in cash.
_________________________
CRCM

Return to Top
#599517 - 08/15/06 06:21 PM Re: Weird CTR but hopefully YOU have the answer!
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You don't; this is not CTR reportable. This scenario is addressed in FinCEN's guidance somewhere (the FAQ I think).

If you see any large checks that, if combined, would equal over $10,000, I would document payees on the report. This can be problem with some businesses (such as real estate agents) and with employee bonuses at the end of the year.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#599518 - 08/15/06 06:31 PM Re: Weird CTR but hopefully YOU have the answer!
Dip Offline
Power Poster
Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
Thanks! I'll just jot this down on the report and file it away I love it when things are that easy!
_________________________
Dabbling in banking, law, accounting...the life of a trustee.

Return to Top
#599519 - 08/15/06 06:55 PM Re: Weird CTR but hopefully YOU have the answer!
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I have that happen pretty often. I print out the images of the cashed checks and file them with my report to document why a CTR was not needed.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top
#599520 - 08/15/06 07:08 PM Re: Weird CTR but hopefully YOU have the answer!
Dip Offline
Power Poster
Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
That's exactly what I did
_________________________
Dabbling in banking, law, accounting...the life of a trustee.

Return to Top

Moderator:  Andy_Z