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#1796612 - 03/20/13 04:23 PM CTR Question
Crys86 Offline
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Joined: Jul 2012
Posts: 12
I have a weird situation that has come up and I am trying to determine if I should file a CTR or not. Around 9:00 am a gas station/convenience store employee came in to make the daily deposits into the business account (which is a corporation). There was a total of $4,759.00 in cash brought in at this time by the employee.
About 9:40 one of the business owner's came in with $6,000.00 cash and first deposited it into her personal account but then made the comment that she knew there was a large debit going to be coming through the business account and she needed to transfer the money over to the business instead, so she did a dda debit ticket at the teller window and transferred the $6,000.00 over to the business dda account.
Would I file a CTR knowing that the deposit was actually cash even though it was not directly deposited as cash into the business. Also, if so how would I fill out the CTR form correctly because it is actually not a direct cash deposit, it is a deposit resulting from a transfer which of course is not going to be an option. Thank you all so much, I really do appreciate any help that you have to offer!!

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#1796649 - 03/20/13 04:57 PM Re: CTR Question Crys86
BFrame Offline
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BFrame
Joined: Nov 2011
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USA
I would file the CTR, personally. The individuals came in with cash that, through the course of the transactions, ended up in the business account.

I'd treat this similarly to the idea that some people come in with cash, deposit the cash, then do a debit to create a cashier's check. If the cash was between $3,000-$10,000, you would still complete a Monetary Instrument Log on the purchase.

I would complete a section on the Business ($10,759.00 cash in)
A section on employee ($4,759.00)
A section on business owner ($6,000).
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#1796650 - 03/20/13 05:00 PM Re: CTR Question Crys86
BFrame Offline
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BFrame
Joined: Nov 2011
Posts: 402
USA
Just one other comment:

I'd be suspicious if this activity happens more than once. Could the business owner be trying to avoid a CTR being completed by depositing to another account then transferring the money?

In this case, if I were the teller, I'd have reversed the deposit and done the correct deposit to the account that the customer intended, which would have cleared up confusion about the CTR.
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#1796698 - 03/20/13 06:00 PM Re: CTR Question Crys86
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As the transaction was completed, no CTR should have been filed.* However, if there is anything that leads you to the idea that structuring may have been involved (as ItsOK suggests), get the information to the people at your bank who determine when SARs are filed.

*CTRs are filed based on actual cash transactions, not on what happens afterward. The same cannot be said about the record keeping requirement for cash purchases of monetary instruments.
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#1796765 - 03/20/13 07:34 PM Re: CTR Question Crys86
BFrame Offline
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BFrame
Joined: Nov 2011
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USA
Thanks for the clarification, John, on the diff. between the CTR and the requirements for monetary instrument logs.
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#1797006 - 03/21/13 02:05 PM Re: CTR Question Crys86
Crys86 Offline
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Joined: Jul 2012
Posts: 12
Thank you so much for the information, I do appreciate!

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