Skip to content
BOL Conferences
Thread Options
#497733 - 02/13/06 01:11 PM ID from CTR customer
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
A business dropped deposits into the night depository. Later in the day, an employee dropped off more deposits for the same business that were locked bags through the drive-in. Deposits that were dropped off exceeded $10K in cash. Does the person dropping the bags off need to be put on the CTR under the person conducting the transaction?

Return to Top
BSA/AML/CIP/OFAC Forum
#497734 - 02/13/06 01:17 PM Re: ID from CTR customer
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The only reason you don't have to ID the person conducting a deposit via the night depository is that you can't reliably know who did it. With a "drop off," you have at least a chance of knowing who the transactor is. That person needs to be identified on your CTR.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z