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BSA Reporting of Foreign ATM Deposits

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Regarding foreign ATM deposits of more than $10,000, we have no way to identify if they were made by cash or check. Is there any responsibility for BSA reporting in these instances?

Yes, the ATM host bank knows of the cash deposit and your bank has the customer information. Network rules should provide guidance on reporting cash deposit information to the card-issuing bank. FinCEN issued guidance relating to agency banks that accepted deposits from the customers of another institution. Each institution had CTR-filing responsibility, but FinCEN said they can agree between them who will actually file. That's very much analogous to the interchange deposit question you raise. See FinCEN Ruling 2001-1.

First published on 3/22/10

First published on 03/22/2010

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