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#2298809 - 06/27/24 03:46 PM Cash Advance - CTR
Lele131 Offline
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Joined: Feb 2023
Posts: 12
Do you have the entire credit card number listed when you do a CTR for a Cash Advance? I want to write procedures for completing a CTR in different instances. Branch was initially just listing a partial number. I looked through FinCEN for CTR completion but did not find anything relating.

TIA!

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#2298840 - 06/28/24 12:52 PM Re: Cash Advance - CTR Lele131
NatalieJ BSA Offline
Member
Joined: Apr 2016
Posts: 92
This is not a scenario that I've ever encountered or seen mentioned specifically by FinCEN. That being said, I'd list the entire card number involved in the reportable activity, just like I'd list the entire bank account number/numbers involved in the reportable activity.

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#2298853 - 06/28/24 03:00 PM Re: Cash Advance - CTR Lele131
ColoradoAML Offline
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Joined: Mar 2018
Posts: 367
FinCEN's filing instructions say to enter the account number. Since they don't say anywhere that a truncated or partial account number is acceptable, I would assume it's not. If someone reviewed the CTR and sent a subpoena with the number you provided on in, you don't want to risk someone in the subpoena department replying that the account doesn't exist.

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