Posted By: Spenser
"Correspondent Banking" - 07/18/07 09:24 PM
I am the BSA officer for a medium-sized community bank. We have agreements with two large commercial banks, which allow our business customers, who are not near any of our branches, to make deposits into their branches. The deposited amounts are then transferred to our bank, via the Internet, and credited to our customers' accounts the following day. Our internal auditor listed as a 'finding' the fact that we can't be sure that a customer isn't depositing cash into one of our branches, and on the same day depositing cash at a "correspondent" bank branch, to a total of over $10,000. If each cash deposit was less than $10,001, neither bank would know that a CTR should have been filed. When we receive the deposit information, we see only a total, not a cash/check breakdown.
Does anyone else offer this service? And if so, do you have a way to mitigate the risk of missing a CTR? We would like to close this open finding. Can anyone offer some input?
Does anyone else offer this service? And if so, do you have a way to mitigate the risk of missing a CTR? We would like to close this open finding. Can anyone offer some input?