Thread Starter: CULady
Title: Re: CTR for person w/ protected address
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Safest bet is to call FinCEN and/or your regulator. Everything else is just guess work from the peanut gallery (myself included!).
I would mark Unknown (it's not technically wrong!). Then I would update my CTR policy and procedures and note how we handle these accounts and do the same for all of them going forward.
My two cents: Even if FinCEN/regulator were to find this one CTR, it hardly shows a systemic failure of BSA and would not warrant a finding.
I think I would file it and move it to the next big issue.  Good luck!
If you do happen to call FinCEN or your regulator, please update us! I'd love to hear their thoughts.
-K
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