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#961427 - 05/19/08 07:09 PM Another CTR question
Paris Offline
100 Club
Joined: Dec 2005
Posts: 173
Honolulu HI
A customer made a large (reportable) cash withdrawal from his individual account.

The customer's wife was standing with him at the teller window as he received his cash withdrawal. She is not on his account and is not a customer.

Would we have to report the wife as benefiting from the transaction on the CTR too?

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BSA/AML/CIP/OFAC Forum
#961482 - 05/19/08 07:58 PM Re: Another CTR question Paris
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Unless the teller saw him hand it to his wife or overheard something about the purpose of the withdrawal,I would say no.

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#961881 - 05/20/08 02:32 PM Re: Another CTR question nemsi
alliedog Offline
New Poster
Joined: Nov 2006
Posts: 8
Somewhere
I agree with nemsi - we would not include the wife unless we knew for sure.

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#961984 - 05/20/08 04:35 PM Re: Another CTR question alliedog
Little Miss BSA Offline
Diamond Poster
Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
Knowledge is key - and unless you have knowledge that she would be benefiting from those funds, then No I would not include her in the CTR.
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