We have three restaurants that are owned by the same individual, and each of the businesses has a cash deposit just about every day. Our operations manager wants our tellers to combine the cash deposits of the three companies for CTR filing, because the same individual benefits from deposits to all three accounts. Is that correct?
I seem to remember a FinCEN ruling concerning CTRs that specifically addressed Negotiable Instruments versus Withdrawals. For instance, if a client is withdrawing funds from his own account at our institution, when should we check negotiable instrument cashed and when should we to check withdrawal? Please direct me to the ruling or provide guidance.
If a customer cashes a check of over $10,000 on his own account at our bank, is it a problem to check both box 32 and 34 on the CTR? It is a withdrawal and a negotiable instrument is cashed, so it seems that by checking both boxes it makes it more clear as to what the customer actually did, rather than just checking box 32, which could imply he cashed a not-on-us check. FinCEN told our auditor it was not really a problem, but our independent review person says it is not correct. What is your opinion?
This section of the SAR Activity Review provides information related to potential terrorist financing activity. This information has been obtained from a variety of sources, including:
We currently use armored carrier services for our MSB customers when ordering cash. For CTR reporting, we report on "delivery date" Vs "order date". Going forward, we are conducting research and looking to report our CTRs on "pick and pack", which is the date funds are actually removed from our vault, but not delivered to the customer. Would this change be acceptable to the IRS?
I understand that there was a recent CTR filing ruling from FinCEN regarding DBAs. Where can I find this?
Regarding foreign ATM deposits of more than $10,000, we have no way to identify if they were made by cash or check. Is there any responsibility for BSA reporting in these instances?
I've been in banking for many years and cannot recall ever having a church on the exempt list for CTR filing. I have a branch requesting that their local church be considered. I am unable to find anything in the FFIEC Manual stating specifically that we cannot, but for some reason I don't feel right about it. Are you able to provide me some guidance?
It is my understanding that FinCEN put out a ruling on CIP address confidentiality programs (ACP). Where can I find this ruling?