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#2002650 - 03/19/15 04:25 PM Private Courier vs Armored Car
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Despite all of what I've seen from FinCEN and in this forum, it doesn't appear that any other new guidance has come out on this topic. With that in mind, am I still okay with the following:

If the 'conductor' is a private courier, which is contracted by the customer, then the 'conductor' is the invididual who is making the delivery, not the actual courier service entity. It is that individual from whom identification must be provided on the CTR. And if we can't get information on the individual, then the conductor becomes "unknown" and 'private courier' is still checked.

If the 'conductor' is a courier (real armored car or not) which is contracted by the bank, then the conductor is the individual at out customer's who gave the courier the deposit.

The 'conductor' is NEVER an entity, always an individual.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#2002692 - 03/19/15 06:09 PM Re: Private Courier vs Armored Car Doug Hendrickson
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
Have you read FIN-2013-R001?

This states under "Exceptive Relief Granted for the Completion of CTRs on Certain ACS Transactions" #3 on the 3rd bullet point that the courier service entity information is acceptable and the employees name will not be needed.

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