CTR Question

Posted By: BOL User V2

CTR Question - 05/13/22 06:58 PM

We routinely ask customers the purpose of large cash withdrawals over the CTR reportable threshold. We do this as a customer service to inform that carrying out that amount of cash is not safe and also ask in order to prevent possible elder financial exploitation.

We had a situation recently where a customer withdrew $40K in cash from his joint account. He stated that half would be going to his ex-wife, a non-customer.

Are we obligated when filing the CTR, to included the ex-wife's information on the CTR since we have knowledge that she is benefitting from the cash transaction?

Thanks so much!
Posted By: Sunshine Lady

Re: CTR Question - 05/13/22 07:41 PM

No, you only have to file on him because he is the one who took out the money. Just because he said that does not mean he is going to give her half.
Posted By: ColoradoAML

Re: CTR Question - 05/13/22 07:47 PM

I agree with Sunshine Lady and would add that even if he does give her half, the transaction is still on his behalf so that he can pay her. If I withdraw cash to buy a car, the transaction is on my behalf so that I can make the purchase, not on the seller's behalf.
Posted By: unknown

Re: CTR Question - 05/16/22 03:47 PM

If customer deposits $20,000 cash and then takes $5,000 cash from the deposit. Total cash deposit showing in the customer’s history is $15,000.

Teller ran it with cash in ticket and cash out ticket at the same time.

How would you complete this in Part III?

25a deposit - $15,000
25e currency exchange - $5,000


OR

25a deposit - $20,000

???
Posted By: Sunshine Lady

Re: CTR Question - 05/16/22 05:55 PM

I would completed it using your first example. That is how we do it.
25a Deposit - 15k
25e Currency Exchange - 5k
Posted By: John Burnett

Re: CTR Question - 05/18/22 02:58 PM

Originally Posted by Sunshine Lady
No, you only have to file on him because he is the one who took out the money. Just because he said that does not mean he is going to give her half.
I suggest you go back to re-read Q&A 24 in FinCEN's CTR filing FAQs. It would not be incorrect to assume the customer's statement that half of the money was being withdrawn on behalf of his ex-wife is correct, especially if she is the other owner of the joint account described by the OP, and include a Part I section for her.
Posted By: John Burnett

Re: CTR Question - 05/18/22 03:00 PM

You might also ask the customer if he wants to close the account out and open a new one in his name only.