Skip to content
BOL Conferences
Thread Options
#650045 - 12/11/06 01:00 PM CTR (cash outs)
mobdiaz Offline
Member
Joined: Apr 2004
Posts: 53
I recently changed employers and found that my new employer does not investigate multiple cash outs to identify if any one beneficiary received the cash (typically through cashed checks). At my former employer, we looked at copies of cashed checks to see if a single beneficiary performed the transactions. I understand that if the institution has knowledge of the multiple transactions performed on behalf of one beneficiary, we are obliged to file the CTR; however, at what point do we become responsible for knowing? How much investigating do we need to do?

Thanks!

Return to Top
BSA/AML/CIP/OFAC Forum
#650118 - 12/11/06 03:51 PM Re: CTR (cash outs) mobdiaz
Bobw Offline
Gold Star
Bobw
Joined: Nov 2006
Posts: 336
New England
I can tell you large banks do not check to that detail, they do cover it in the Risk Assessment. I used to work for a very large credit card issuer and there was a question from our internal audit about checking for checks that came in for payment. We processed millions of payments automatically each month and there was not way...just included it in risk assessment and felt the risk was low based on vols. I asked the question at a BSA/AML Conf from a FinCEN person and they agreed.
_________________________
just my opinion, based on my 30+ years

GO RED SOX!!!

Return to Top
#650126 - 12/11/06 04:16 PM Re: CTR (cash outs) Bobw
mobdiaz Offline
Member
Joined: Apr 2004
Posts: 53
Any feeling about if it matters that I have the resources to do it or not? Or if my volume is very low? I would love to avoid it, but I know that other institutions in my area (and regulated by the same agency) do it.

Also given that other activities pose greater risks to the institution, I like the idea of recognizing the risk and classifying it as low in comparison other areas desrving attention (transaction monitoring for suspicious activity and EDD).

Thanks again.

Return to Top
#650177 - 12/11/06 05:00 PM Re: CTR (cash outs) mobdiaz
Bobw Offline
Gold Star
Bobw
Joined: Nov 2006
Posts: 336
New England
Sorry, don't really know how they would call it, I work for a much smaller FI now and we do some at the front end, but manual is questionable and not always consistant. If your regulator is looking at this, then I guess that is your answer.
_________________________
just my opinion, based on my 30+ years

GO RED SOX!!!

Return to Top
#650215 - 12/11/06 05:41 PM Re: CTR (cash outs) Bobw
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
My feeling is that if you have the ability to aggregate (either using software, blood sweat & tears, or whatever) you should. If you can do it but choose not to, could it be considered willful blindness?

Return to Top

Moderator:  Andy_Z