A chain of restaurants places their currency deposit in to a smart safe. A 3rd party company that couriers as well as fills and balances ATMs will pick up the currency, deposit it into one of their accounts, and then ACHs the week's total into a GL accont at our bank. Who files the CTR? I said the 3rd party or their bank, but then wondered if the answer would be different if we owned the Smart Safes, and provided them to the restaurants.

Sorry - I am having a hard time following what you are saying. The third party deposits the cash in who's "one of their accounts"?

I think you probably need to review this, which includes the following and also some other references:

In addition, financial institutions must file a CTR for currency received by an armored car service from the financial institution's customer when the armored car service, as an agent of the financial institution, physically receives cash from the customer, transports it and processes receipts, even though the currency may never physically be received by the financial institution.

https://www.fincen.gov/resources/st...treatment-deposits-armored-cars-currency

I apologize for my post being unclear, plus I have additional information. This is something entirely new to me.

The bank is purchasing a smart safe for one of our large currency depositing customers. The customer will put their deposited currency in the smart safe. A company similar to an armored car business will pick up the currency from our smart safe located in our customer's business, and deposit the cash into the armored car company's account at the armored car company's bank. The amount will then be ACH'd into our customer's account at our bank.

Since the smart safe is owned by the bank, would our customer's currency be reportable by us at the time it's put into the safe? Would the safe be treated as if the deposit was made through one of our tellers? Then at the end of the week when the armored car company removes the currency from our smart safe located in our customer's business, would it again be reportable as a withdrawal made by the armored car company?

My thought is that the safe is equal to one of our tellers because we own it. Our customer's currency goes in = CTR. At the end of the week Armored car company takes currency out of our safe and to their bank, so withdrawal by armored car company from our safe = CTR?

Maybe I'm over thinking this, but FinCEN's directives don't address bank purchased safes placed in customer's place of business, with daily currency deposits placed in and weekly withdrawals of the currency made by armored car business. At least I couldn't find anything about smart safes, etc.

The fact that we never physically see the currency is throwing me. It goes from the customer into a safe and then to the armored car's bank account. If it wasn't a safe owned by the bank I wouldn't be asking for an extra brain to think this through.


Thanks again.

I am not sure how this is any different that what is address in the advisory I posted. The armored car company appears to be acting as an agent for the bank and is picking up the cash and processing it on behalf of the bank. I am not sure why the armored car company is withdrawing cash - they are just picking it up at the customer location. This is unless I have no idea how this actually works.

I have several clients that use these.

The CTR is the bank's responsibility. The CTR transaction date is based on when you credit the customer(s) account for the cash deposits. Most of my clients will hold off on filing until closer to day 15 to give the armored car a chance to verify the cash. Otherwize they get stuck filing a lot of amended CTRs because the actual cash count discovers bills stck together, errors in the totals, etc.

The armored car taking the funds out of the safe to verify and count it is moving the money on the bank's behalf. There is no reportable transaction when this occurs.

The part that was throwing me was that the armored car wasn't depositing the currency in our bank, so I didn't know if that meant a second CTR due to their withdrawal from our safe. Thanks so much for clearing the mud for me.