One of our best tellers was duped into giving out $20,000 in cash by a woman posing as our customer. The woman had stolen the customer's dr license and put her own picture on the dr license. The teller asked for the DL and of course the picture looked just like the woman standing there.

Since we can't ID the criminal, do we have to file the CTR? What abou the SAR, since it doesn't meet the threshold?

I would contact FinCEN by phone AND mail and request a determination in writing. I would include a copy of any police report as well to document your letter. Send your letter certified so you can prove your due diligence.

Personally, I think a SAR is more fitting for this situation. A CTR would most likely be inappropriate since fraud is involved.

The threshholds pertain to mandatory filing requirements. You can always file if you want.

Since when does $20,000 not meet the threshold!!!!

They cannot identify a suspect and that falls under the $25,000 threshold.

Duh! Thanks

Call FinCEN about the proper completion of the CTR as you may encounter a field examiner who, based on divine inspriation alone, knows how you should have completed the CTR. Make your own record of the conversation - FinCEN does not dispense written advice unless you go through the formal process of requesting an administrative ruling.