Skip to content
BOL Conferences
Thread Options
#1860561 - 10/10/13 08:14 PM CTR with ATM withdrawal - please help
PeeWee Offline
Gold Star
Joined: Aug 2007
Posts: 254
Our current practice is to report all joint owners on a withdrawal.

Situation: Wife withdrawals $9,800 over the counter from an account held jointly with her spouse. Same day, she withdraws $500 cash at the ATM (her card was used).

Being we've chose to report joint owners, would you list him on the CTR for just the $9,800 or the full $10,300?

We haven't had a sitation like this come up (with an ATM w/d thrown in the mix)...and yes, I'll look at it from a suspicious stand point as well.

Return to Top
BSA/AML/CIP/OFAC Forum
#1860565 - 10/10/13 08:16 PM Re: CTR with ATM withdrawal - please help PeeWee
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
See question 24 from the CTR FAQ's. You are entitled to make the decision you have made; i.e. to report all owners on every withdrawal. You are not required and should not apportion the total amount withdrawn between them (regardless of whose card was used or who was standing at the window).

List $10,300 for each of them in item 22.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1860571 - 10/10/13 08:25 PM Re: CTR with ATM withdrawal - please help Elwood P. Dowd
PeeWee Offline
Gold Star
Joined: Aug 2007
Posts: 254
Thank you, Ken, that helps alot! I really appreciate your input.

Return to Top

Moderator:  Andy_Z