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#640222 - 11/20/06 09:18 PM incomplete ctr
ckme Offline
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ckme
Joined: Sep 2002
Posts: 255
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?

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BSA/AML/CIP/OFAC Forum
#640227 - 11/20/06 09:23 PM Re: incomplete ctr ckme
Big Dog Offline
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Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
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.
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#640230 - 11/20/06 09:27 PM Re: incomplete ctr Big Dog
ckme Offline
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ckme
Joined: Sep 2002
Posts: 255
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.

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#640234 - 11/20/06 09:28 PM Re: incomplete ctr ckme
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
LOL.
And you said .... ?

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#640249 - 11/20/06 09:44 PM Re: incomplete ctr MagicCity
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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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#640388 - 11/21/06 01:10 PM Re: incomplete ctr J2C
Big Dog Offline
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Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
Can you say Structuring?
How about TAX EVASION?
I would love to write up that SAR, using his quotes in big bold letters so the IRS sees it!
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#640409 - 11/21/06 01:50 PM Re: incomplete ctr Big Dog
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,361
Galveston, TX
The SAR is one thing. But as far as the incomplete CTR - that is what checking the multiple transactions box is for.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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