bsa/aml audit

During the course of an internal audit, I noticed a few ctr's that were not filled out correctly (sections A & B). Do we need to correct and refile?

i would say only correct them if fincen sends them back, unless the errors are major (filed or the wrong person, gave a wrong ssn--errors like not marking "multiple persons" aren't major). otherwise, make it a finding in the report and recommend increased training and better control for ctr's

I guess I'm a stickler ... I would recommend that the BSA Officer send amended CTRs. But that's just my opinion.

I agree with Ms Auditor, I have always recommended filing amended reports.

Our last go around with FDIC they recommended re-file. We use E-File and since someone else is doing FinCEN's input they would like zero errors. As they move towrds required electronic filing the tolerance for errors will be less.

Re file. A good examiner will comment on this.

should we refile even on minor errors? i am finishing up my bsa audit and this would be good to know since it would change my final audit report

The general rule is that CTRs should be completed correctly and filed according to the instructions. There is a box for "amended." There does not appear to be any guidance, that I'm aware of, as to what type of error would require filing an amended CTR vs. what type of error would not. Therefore, I believe the safe route would be to file an amended CTR.

From the CTR instructions:

Item 1a. Amends Prior Report. If this CTR is being
filed because it amends a report filed previously, check
Item 1a. Staple a copy of the original CTR to the amended
one, complete Part III fully and only those other entries
which are being amended.

i meant minor as in the teller reported multiple persons in section a but did not mark the multiple persons box--REALLY minor errors like that

I would call the DCC and ask for guidance in writing. They may tell you that for something that minor, you need not re-file.

Do you have a phone number?
Thanks

Sure. 1-800-800-2877

Best of luck!

I'd refile.

Better get them refiled. Be careful with the entire BSA/anti-money laundering topic. The regulators are focusing hard on this topic. I speak from experience (my opinion only). Good luck.

I would re-file on any error you find. There would be no reason I'd see where they would question you amending it but I could see them questioning you not fixing it.