A Mexican Consulent Business has opened an account with our bank. They do not have, and say they don't have to have, a federal tax ID number. Well guess what.............now we are in a situation where we need to file a CTR on this business. How do we complete a CTR without an EIN to report?? HELP!!!!

I'm not an expert on this type of business, but why would they not need a Tax ID number? Even if they did not need it for other reasons, they can still obtain a number for banking purposes.

Our CIP policy requires that they provide us with a number or we would close the account. Check your CIP program to see if this is addressed. If not, I would require them to get a number or close the account. I don't know of any exemption on CTR reporting for not providing a Tax ID number. Maybe one of the experts will weigh in on this.

Hope this helps.

Crazed:

What do you mean by "Consulent" business?

When the person listed on a CTR does not have a TIN, the instructions for items 6 and 19 are pretty clear: "If none, write NONE," and "If the individual does not have an SSN/TIN, enter NONE."

I think they meant to say consulate - which is an account usually maintained for or by a foreign government.

Oh and by the way - these accounts should most definitely be classified as PEPs

Or, we could be going in the wrong direction. A consulate doesn't usually operate businesses. I'm guessing "consultant" or "consultancy" is where crazed is going.

Sorry, I do mean consulant. I guess the instructions are there for a reason. I was taken off guard when I seen a CTR had to be completed.

Can you explain the classification of a PEP? I know this stands for politically exposed persons. What are the requirments of a financial instituion that has accounts classified as a PEP?