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Paying Employees by Checks Drawn Off Same Acct.

We have a business that pays their employees by checks drawn off the same account. The employees sign the checks and gives them to the same person to cash the checks for them. The total of all the checks is >$10,000. The person bringing the checks into the bank to cash them, signs under the employee's name on all the checks. How should the CTR be completed? Is she the conductor for all the employees or is it on her own behalf?

by Randy Carey:

She is the conductor for all the employees in this case. You need the identification information for each employee. What they should be doing is depositing these checks into their account and taking one withdrawal out of the account on behalf of the business for payroll check cashing purposes.


by Ken Golliher:

My read is that the employee presenting the checks is cashing them on behalf of each individual co-worker and every single payee should be listed on the CTR along with their identifying information. (My secondhand understanding is that the Helpline might give you a different answer.) Either way, I will stick with my answer.

Regardless of how a bank might fill out a CTR, this is a lousy banking practice. It facilitates:
* padded payrolls,
* employment of undocumented workers, and
* human trafficking.

Moreover, if one or more of the payees' signatures are forged, your recourse is against the last endorser and you are in the middle of the disagreement about whether the signature was forged or genuine. Assuming the employer is your customer, I suggest you give them a call and indicate you will not do this any more.

First published on 12/30/2018

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