Skip to content
BOL Conferences
Thread Options
#2252402 - 04/15/21 02:34 PM CTR Scenario - overthinking / complicating this
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 236
I am having quite an argument in my own head about this scenario:

Is it possible to have three part 1s for one person? Customer conducted deposit on own behalf, customer conducted deposit on behalf of another (his business), and account owner on behalf of (as someone deposited funds to personal account for customer)?

This seems like over kill and I'm questioning if I am overthinking and overcomplicating this scenario?

Customer A deposited $12,000 to his business account and $5000 to his personal account (conducted on behalf of another, conducted on own behalf)
Customer B deposited $1500 to Customer A's personal account (account owner on behalf of and customer B would be conducted on behalf of another) - or is this transaction left off the CTR because Customer A's personal account only received $6500 in cash deposited total?


Thank you! What a morning!

Return to Top
BSA/AML/CIP/OFAC Forum
#2252404 - 04/15/21 02:59 PM Re: CTR Scenario - overthinking / complicating this SmallBankBSA
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
In this example, you are correct that the $1,500 is excluded. However, if customer B had deposited $6,000 to Customer A's personal account, then Customer A would have had more than $10,000 deposited on their behalf and you would have ended up with three Part I's for Customer A.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2252411 - 04/15/21 03:49 PM Re: CTR Scenario - overthinking / complicating this SmallBankBSA
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 236
Thank you! I knew I was overthinking this CTR!

Return to Top

Moderator:  Andy_Z