If a POA conducts a $12,000 cash withdrawal for a customer and the ticket says it was authorized by our customer, would you list the customer as the benefactor and the POA as the transactor? If we do this, JH Teller is not providing a 2 c option for Person on whose behalf transaction was conducted.

We could list the POA as a benefactor since they left with the cash, but she should not benefit from the funds as a POA.

There are no benefactors on a CTR. It is not the POA's money. They transacted on behalf of the account holder. If they did not, then they violated their fiduciary duties.

So Part 1 is our customer. They were not present, so what do we put for form of identification? They were a customer prior to CIP.

Do we do another part 1 and mark the POA as conducting the transaction?

Your customer is Part 1/c Use the information you have in your system. You should have at least the DOB & SSN. If the ID you have on file is expired, you can list unknown. If it is like Illinois, unless their last name first letter has changed, the number would not have changed.

POA is Part 1/b.

" If the ID you have on file is expired, you can list unknown. "

If you have an ID on file you list it. There is no requirement to have a record of an unexpired ID to file a CTR.