Skip to content

Completing a CTR When Identity Unknown

Answered by: 

We recently had a member come in and pay off her auto loan in cash, $10,500. She however had a non member with her who had the cash in her possession and handed it to the teller. When asked to produce ID for the large sum of cash she said that she did not want to. She would be the conductor but her identity is unknown. How should the CTR be filled out?

This is not a complete answer--just some thoughts about how to approach the question.

Isn’t the member the conductor? The member’s source of funds is a separate consideration and may, itself, be the subject of a report.

Let’s say the mystery woman is an employee of another financial institution and that other institution is taking your loan out. If you report your member as conductor of a cash-in transaction and the other institution reports your member as a conductor of a cash-out transaction, the CTR database will contain a clear accounting of what happened.

First published on 3/7/11

First published on 03/07/2011

Filed under: 
Filed under security as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics