SITUATION:

Supervisor for a business walks in with 15 checks, 15 different payees - all who work for his company. They have endorsed the checks and he is cashing them for the individuals.

How are you filing the CTR?

1. Conductor standing in front of you and conducted on own behalf since you can't "assume" the others are getting the funds?
2. Conductor standing in front of you and then asking for complete information on each payee so you can enter multiple beneficiaries?

THEN - what if he does not have the information handy OR states some of them do not have SSNs?

Yes - I know if they are working they should have a SSN - so then are you refusing to allow him to cash the checks?

This is a rabbit hole I know BUT we received criticism for incomplete / inaccurate CTRs and are attempting to always get complete information. In this situation, it is not always available.

Last time - he admitted they were employed without SSNs so we then filed a SAR.