Is a Mexico drivers license a valid ID for CTR purposes and if so, would this be a line 14(d) item? The normal IDs one would expect, matricular or nonresident alien work card, are not available in this case.
We have a business account for an LLC that offers "financial and legal consulting". It was explained that they are heavily into loan modifications at this time. There are three members (one is an attorney) who have signing authority over the account. We noticed a high volume of debit card activity and most of it appears to be for personal as opposed to business purposes. For example, there are many POS purchases at high end stores such as Coach, Burberry, Saks 5 Avenue, plus many restaurants, spas, ice cream shops, etc. We asked the branch if they knew the purpose of this activity and they answered that they are for gifts for business referrals. To me this is nonsense. There are also many ATM withdrawals for the maximum daily limit ($600) that also do not appear to be for normal business purposes.I recall posting questions on BOL in the past about similar activity, such as college tuition payments from business accounts and the general consensus was that this should not be the bank's concern and should not result in a SAR filing (for tax evasion or avoidance). What is the consensus about the activity described above?
Can you offer a best practice answer to customers who ask about CTR reporting requirements? Example: How much can I deposit or withdraw without it being reported?