Skip to content
GeoDataVision
Thread Options
#971389 - 06/09/08 01:02 PM CTR Benefactor
MoodyBlue Offline
100 Club
Joined: Jul 2006
Posts: 183
Below the Mason Dixon Line
John Doe brings in $35,000.00 in cash and purchases 3 Cashier's Checks for Mickey & Minnie Mouse. Since the checks are for the benefit of Mickey & Minnie Mouse shouldn't they be the benefactor and John Doe the transactor. Also, if there is a SAR filed for this activity should Mickey & Minnie be reported along with John Doe. Thanks!!!!

Return to Top
BSA/AML/CIP/OFAC Forum
#971538 - 06/09/08 03:44 PM Re: CTR Benefactor MoodyBlue
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
For a CTR you need to describe two types of persons -- In section A you must provide the name(s) of the person(s) on whose behalf the transaction is conducted (use of the words "beneficiary" and "benefactor" is inaccurate and the cause of lots of misunderstandings on who gets reported on a CTR). And in Section B, you describe the individual or individuals who conducted the transactions.

I read your question to say that Doe is buying the checks on behalf of the Mouses (or is that "Mice"? ). That is, the Mouses asked him to purchase the checks for them. In that case, Mickey Mouse would be in one Section A entry and Minnie Mouse in a second Section A entry, with John Doe in Section B.

On the other hand, if your question should be read to say that Mickey and Minnie Mouse are the payees on the checks and that John Doe is buying the checks to pay Mickey and Minnie Mouse from his own funds (he owes them money or wants to give them the money), then John Doe conducted the purchase on his own behalf, and John Doe only goes in Section A, with Section B completed with a single check of the "conducted on own behalf" box.

If I have misread your question, please clarify for me.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#971576 - 06/09/08 04:20 PM Re: CTR Benefactor John Burnett
MoodyBlue Offline
100 Club
Joined: Jul 2006
Posts: 183
Below the Mason Dixon Line
I filed with John Doe as benefactor & own behalf. Was just questioning myself. The teller stated that the checks purchased with cash were from John Doe for Mickey and Minnie Mouse (out of state residents) for school. Three checks are for $9,000.00 and one is for $8,000.00. John Doe stated that he would have purchased one check but Mickey and Minnie wanted four separate checks. Thanks!!!!

Return to Top
#971597 - 06/09/08 04:42 PM Re: CTR Benefactor MoodyBlue
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
in that case ... maybe a SAR filed on Mickey & Minnie is appropriate ... something doesn't feel right ...


* side note

What part does Donald Duck play in all of this? (hah hah - couldn't resist that one)
_________________________
My opinions are my own, and not that of my employer.

Return to Top

Moderator:  Andy_Z