we have a situation where a person intentionally cashed two checks on the same business at two different branches. we have everything to complete the ctr except his ssn. What do i do? Submit the incomplete ctr and then a SAR? just a SAR?
You are required to file a CTR. Call and ask for the SSN if you have his contact information. SAR would be completed if you feel the transactions were conducted in a way to avoid a CTR.
WE CONTACTED HIM AND HE INDICATED HE DID IT SO THERE WOULD BE NO PAPERWORK AND HE DOES NOT FILE INCOME TAXES. HE SAID HE WOULD BRING THE CASH BACK AND WE COULD GIVE HIM A CHECK TO CASH ON ANOTHER DAY. YIKES.
Did you get his driver's license? Obviously he is avoiding the reporting, I would file the SAR with the missing TIN and indicate that in your write-up....provided you have everything else. I assume he is a non-customer...or you would have the TIN???
I certainly would NOT let him come back for a bank check.
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My opinion is mine only- not my employer's!