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CTR on an Attorney Escrow Account

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When completing a CTR for a cash deposit to an attorney escrow account where the funds belong to the attorney's client and we have no knowledge of who the client is, who should be reported in Section A? Do we need to ask the attorney for his client's information?

The attorney's client is a person on whose behalf the deposit is conducted; therefore, you must inquire on, and the attorney is obliged to provide identifying information on the client sufficient to complete a Section A entry for the client. In addition, of course, you include a Section A entry on the attorney or his/her law firm (depending on who owns the account). Refer to Administrative Ruling 89-5, Example 3, which can be found here in Appendix A to 31 CFR Part 103.

If the attorney or law firm refuses to provide the information you need to complete the Section A entry on the client, you should consider escalating the matter to an officer or manager in your institution with the appropriate experience and authority to deal with the attorney and who can explain that the attorney should review the federal penalties for causing or attempting to cause a domestic financial institution to file a report required under Sec. 103.22 of 31 CFR Part 103 that contains a material omission or misstatement of fact. If that contact does not convince the attorney to provide the required information, it would be appropriate, I believe, to file a SAR, after filing the CTR with a cover letter explaining why required information is not included.

First published on 5/25/09

First published on 05/25/2009

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