09/15/2024
A husband and wife come to the bank. The wife has an account with us the husband does not. The wife withdraws $10,000 from her checking account. Then she and her husband cash three checks not drawn on us but made payable to both of them totaling $2,500. I know we will include this on the CTR under her Part I, but should he be listed on the CTR? He only benefited from the $2,500 but is that transaction tied with her for the CTR?
07/07/2024
I have a CTR question. Husband writes a check to Wife for $10,000.00 and she cashes it. Husband then uses the ATM to withdraw $600.00 from his debit card. There is no way to know if both of them are benefiting from each transaction.
Would a CTR be filed?
06/16/2024
I know this question has been asked before but I'm having issues with explaining this to one of our Financial Managers. When a reportable cash transaction is made into a joint account, we need all the joint account owner's information in order to complete the CTR for filing. Am I correct?
04/28/2024
We have a client who deposited over $10K into the "Estate of XXXXX" account. When creating the CTR is the Estate the beneficiary on the CTR? The only other person on the account is the Executor.
01/07/2024
Can we re-disclose information from beneficial ownership secure system?
01/07/2024
What are the next steps for beneficial ownership?
12/31/2023
When can a financial institution request information from FinCEN?
12/31/2023
What are examples of types of transactions financial institutions cannot use beneficial ownership rule?
11/12/2023
Would a CTR be required if several individual employees endorsed their respective payroll checks (all individual payroll checks are under $10,000 but combined they aggregate to an amount that exceeds $10,000), and the owner of the business (which is exempt phase 2) cashed them for the purpose of distributing the proceeds back to the individual employees?
Is this allowed under an exemption?
PS - Our Compliance BSA Officer abruptly left the bank with no guidance, and we are trying to make sure we do things correctly.
09/17/2023
Customer A and Customer B (a married couple) open two single-owner CDs with cash. Customer A's CD is opened with a CTR-reportable amount of cash. Customer B's CD is opened with $5,000 cash. Would Customer B, Customer B's CD, and the cash used to open Customer B's CD be included in the CTR?