Non-Customer Minor on CTR

Posted By: Craney

Non-Customer Minor on CTR - 10/13/21 09:30 PM

We have a scenario where two non-customer's cashed an on-us check. One is a minor and the other is the parent, and the check was made out to both of them. We have the SSN of the parent, but the tellers did not get the SSN of the minor. We've been trying to get ahold of the customer, but had no luck. We are running up against the 15 day deadline. Are we "okay" to file the CTR without the minor's SSN?
Posted By: lokes

Re: Non-Customer Minor on CTR - 10/13/21 10:02 PM

Yes, you can file with the SSN as unknown. The below instructions are from the FinCEN CTR Filing Instructions (page 110 on the pdf and page 98 on the actual document). https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf

*15. TIN (enter number in space provided and check appropriate type below)
a. Unknown
Item *15 TIN: Enter the person's U.S. or foreign taxpayer identification number (TIN) without formatting or
punctuation. If the number is unknown, check box 15 “Unknown” and leave Item 15 blank. See General Instruction 12
for information on entering identifying numbers.

Hope this helps!