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CTR if 2 People Cash Checks at Same Teller Window?

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Two non-customers came into the branch. Each has a check payable to themselves for $6,000 from the same attorney. They go to the teller window together and each person cashes their check. They are together at the window the entire time. Does a CTR need to be filed because they were conducting the transactions together?

The only circumstance under which I would consider it necessary to file a CTR with that set of facts would be if, for some reason, each payee was actually acting on behalf of the attorney who issued the checks. That would be highly unlikely, but I suppose it could happen. So, if the teller were to query, "You guys are here together cashing these checks from the lawyer. Are you cashing them for the lawyer, or is this your money?" and the payees were to respond, "The lawyer asked us to do this for him because he needs the $12 grand in cash but doesn't want any reports filed on it," THEN you would have not only a CTR to complete identifying the two payees as conductors and the attorney as the "person on whose behalf ...," but you're BSA officer or committee should ponder filing a SAR for structuring.

But in the absence of such nefarious goals, if the two payees are simply there together because they just got given their piece of the funds being distributed by the attorney, I would treat them as two individual transactions by the two payees, each on his own behalf and on behalf of no one else. No CTR.

First published on 05/26/2019

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