A CTR filing is required for a customer for a certificate of deposit made using a $15,000 cash brought in. Would it fall under "negotiable instrument"? The customer also wanted a copy of her statements. She gave $2 cash for the fee, would this fall under "payment"? Need clarification since our auditor did not consider certificate of deposit purchased a negotiable instrument.
Our customer buys cashiers checks where he is the remitter and payee. Is he hiding money?
Do we run Customer Identification Program (CIP) on signers?
Can our customer be considered to be structuring under our cash rule of $7500? In other words, we gather info on the customer at $7500 in case of a multiple transaction. She has been depositing several times in amounts of $7400 in cash.
After watching the Top Gun conference pertaining to CTR completion updates, my collegues and I were discussing how we are doing CTR’s with multiple dba’s. Today the system adds both of the entities under one Part 1 of the CTR with a semi colon separating them. Now we understand if we say we have already implemented the ruling then we need to a separate Part 1 for each of the dba’s? This will be a lot of manual work and just want to make sure we understand the update correctly.
Our customer gave his account number to a cousin and the cousin had $250,000 of unemployment come in and out of the account? Will our customer go to jail?
Are beneficial ownership rules changing?
Are CTR and SAR limits changing?
If a customer asks how much they can deposit to avoid the bank from filing a Currency Transfer Report, should we tell them? I thought I couldn’t verbally give them the amount since it could encourage structuring.
I have a CTR scenario that I need guidance on:
John Doe comes in and deposits $10,500 in cash into two different accounts. He deposits $9000 into an account that he owns by himself. He deposits $1500 into an account that he jointly owns with his girlfriend Jane.
Does a Part One need to be filled out on the girlfriend Jane?