CTR Involving Cash Vault Services

Posted By: BSA Aficionado

CTR Involving Cash Vault Services - 08/05/15 07:31 PM

FI offers cash vault services to its business customers whereby:
• FI maintains a cash vault at Brinks.
• FI's business customer privately contracts with an Armored Car Service of their choice to pick up currency deposits from their business location and deliver to FI's cash vault location at Brinks.
• Brinks verifies the currency deposit.
• Brinks uses a tracking system which will be monitored by FI's back-office area. The customer’s account will be credited by this back-office area. The credit to the customer’s account will take approximately one day from the time the deposit is received by Brinks.

When completing the CTR:
• In instances whereby the business customer utilizes the same ACS as the FI (Brinks), should a Part I be completed for the business customer and a second Part I for Brinks? Should the Armored car (FI Contract) box be checked under Item 24 in Part II?
• In instances whereby the business customer utilizes a different ACS, should a Part I be completed for the business customer and the ACS privately contracted by the business customer (e.g., Loomis)? Should the Armored car (FI Contract) box be checked under Item 24 in Part II?
• What should be reflected in Part III of the CTR to illustrate where the cash vault deposits took place?
Posted By: BSA Aficionado

Re: CTR Involving Cash Vault Services - 08/05/15 07:40 PM

FinCEN is indicating that two Part III's should be completed for the same FI, as follows:

-First Part III entry should reflect legal name of FI under Item 30, either the address of the back office location crediting the customer or the customer's branch of domicile for Items 33-36, and the FI's RSSD # for Item 39. *FI does not have a unique RSSD # for the back-office location.

-Second Part III entry should reflect legal name of FI under Item 30, "Brinks Cash Vault" under Item 31, and the address of the cash vault location receiving the deposit for Items 33-36. RSSD # would be left blank.

I'm curious to know how others are handling this?
Posted By: kw004h

Re: CTR Involving Cash Vault Services - 08/05/15 07:57 PM

Interesting. About a year ago, I posed the same question to FinCEN.
Prior Thread

There was no mention of more than one Part III, but we were told to use the address of the location where the transactions was really processed (the vault location), even if it is not an official "Bank" location.

Clearly their stance on this has evolved. Go figure!
Posted By: BSA Aficionado

Re: CTR Involving Cash Vault Services - 08/10/15 05:10 PM

kw004h - Do you complete Parts I and II of the CTR as I describe above?