A customer came in to cash a check and was receiving over $10,000 back in cash. When completing the CTR the DL the customer gave the teller had expired. The CTR does not have a place for an expiration date and the instructions only mention an official document.

Would this be acceptable ID for CTR purposes?

Thanks

I don't believe so because it was not a valid ID.

Would you accept an expired DL for purposes of ID when cashing a check for a non-customer? If not, you should not accept it for purposes of checking ID for a CTR.

John is correct - the instructions indicate that:

Acceptable forms of identification include a driver’s license, military and military/dependent identification cards, passport, state issued identification card, cedular card (foreign), non-resident alien identification cards, or any other identification document or documents, which contain name and preferably address and a photograph and are normally acceptable by financial institutions as a means of identification when cashing checks for persons other than established customers.

Unlike the CIP regulations, there is no mention that the identification document has not be "unexpired".

When BSA usually uses an adjective like "physical" in connection with an address or "unexpired" in connection with identification, but doesn't repeat it at every opportunity such as in wire transfer record retention or CTR completion respectively, I suggest you assume the missing adjective. Any other decision may cause you to waste some time down the road.

Expecting someone who probably drove to the bank to have a valid driver's license does not impose much of a burden.

Is the person a "Customer or NON-Customer"

If a customer, then is a matter of matching the information present to cash the check against the information presented at the account opening.

If a non-customer, then I have to agree with the rest of the posters. A valid ID is "preferable"...