CTR for a dead person

We have a situation where the surviving partner/account executor of our deceased customer cashed a transit check payable to our customer that triggered a CTR. Shouldn't have happened, but a higher-up approved it. For the CTR, we are using "conducting on behalf of another" for the partner. Do we include the dead customer as "person on whose behalf?" There is an estate account for her -- do we use the estate info and EIN instead? I've never had a CTR like this one before. And the partner/executor is also a customer, just FYI.

Sounds like you already know this, but if the decedent's creditors go looking for funds in the estate and there isn't adequate funds to satisfy all the outstanding debts, they will be knocking on your bank's door with a lawsuit for improper conversion of this check.



Nor should you ever have one like it again (see comments above)



Although I majored in theology and was on a track to go to seminary prior to going into banking, I won't have a theological discussion on what is done on behalf of dead people. This side of the afterlife, nothing is done on behalf of dead people because they are dead. Was the check cashed on behalf of the estate? If so list the estate. If the partner cashed the check on their own behalf and took the money and ran, then the CTR would be on the partner conducting on own behalf and your institution will be sweating out the issues raised in the first question above until the statute of limitations for a creditor to make a claim against your bank passes.

When I said that a higher-up approved it, I wasn't giving it my blessing. I was just conveying that it had already been done and my department learned about it after the fact, that it shouldn't have been done, and that we know it shouldn't have been done. Additional training is being done this very moment.

Hence my statement, .

When a higher-up approves something, they don't always take the subordinate's word for it that they were wrong so my answer provides you more ammunition from an unbiased third party.

I frequently use as basis for point "insert BOL Guru name here" states XYZ for issues of this nature...sometimes it works, sometimes I must resort to the next step, which is "nanny nanny boo boo"...