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#2173272 - 04/12/18 07:31 PM Two unrelated persons present
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Larry, who is not a customer, arrives with Joe Customer. Larry hands Joe $20,000 and Joe Customer deposits the cash into his account. Is Larry a conductor? (having a debate over here)
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#2173273 - 04/12/18 07:33 PM Re: Two unrelated persons present ahou
bcompliance Offline
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I would include Larry in the CTR because he originally had the funds that were deposited into Joe's account
Last edited by bcompliance; 04/12/18 07:33 PM. Reason: spelling
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#2173307 - 04/12/18 09:42 PM Re: Two unrelated persons present ahou
ahou Offline
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ahou
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We were thinking If Larry is buying Joe's truck and Joe says 'meet me at the bank' because cash is involved - is Larry really a conductor? He conducted no transaction with the bank.
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#2173311 - 04/12/18 10:14 PM Re: Two unrelated persons present ahou
Daisy Doodle Offline
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Or....Larry could be using his friend's account to do something nefarious. You didn't say what happened to the $20K after it was deposited, but that could weigh into my decision as to whether it's 'sold my car, meet me at the bank' or something worse.

Maybe you have a CTR and a SAR.

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#2173322 - 04/13/18 11:59 AM Re: Two unrelated persons present ahou
bcompliance Offline
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Ask the customer
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#2173323 - 04/13/18 12:15 PM Re: Two unrelated persons present ahou
rlcarey Offline
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Galveston, TX
I agree. There is no way to determine anything after the fact. Either the question as to what was happening was asked at the time of the transaction and information from the individuals was gathered at that time, as deemed necessary, or this is an exercise in futility.
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#2173370 - 04/13/18 01:54 PM Re: Two unrelated persons present ahou
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Thanks for all the comments.
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