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Identifying Info Required-Purchase Official Check

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If a government agency (DEA) sends a representative to purchase an Official Check do we need to get the identifying information on the government representative?

From FinCEN BSA FAQ's:

Question 21: When a federal, state or local government official, as part of his or her official duties, engages in a transaction in currency over $10,000, or purchases a monetary instrument for more than $3,000 in currency, as a non-accountholder, what kind of identifying information must a financial institution obtain?

Answer 21: Government officials sometimes need to conduct large currency transactions as part of their official duties. For example, a law enforcement official may wish to convert seized currency into monetary instruments for security reasons. In such cases, when a transaction in currency over $10,000 is conducted on behalf of a government agency, rather than on behalf of an individual, the financial institution involved in the transaction should file a one-time Designation of Exempt Person form (TD F 90-22.53), to exempt the government agency from the currency transaction reporting requirements and document the basis for its conclusion. Subsequent transactions on behalf of the same government agency would be similarly exempt from the currency reporting requirements. If a financial institution chooses to file a currency transaction report, it generally is required only to obtain, verify, and record identifying information pertaining to the agency for which the individual is working. Thus, any employee identification number, address, or other identifying information obtained should correspond to the government agency involved, and not the government official conducting the transaction.

Notwithstanding the above, a financial institution should still obtain and record the name of the government official conducting the transaction and take those steps that a reasonable and prudent bank would take to verify and document that the customer is a government official conducting business on behalf of a government agency. Regarding the purchase of a monetary instrument for more than $3,000 in currency, a financial institution should record the date of birth of the government official, in addition to his or her name. (8/1/03)

Note the date of publication and remember that it is no longer necessary to file DOEPs or CTRs on government agencies. The philosophy set out in the first paragraph is unchanged, but (aside from using the agency's not the individual's address) only the instructions in the second paragraph remain relevant.

First published on 10/1/12

First published on 10/01/2012

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