When filing a CTR for an escrow account, is the person that is holding the money the beneficiary or just the company holding the money for them?

Both. The escrow agent has control of the funds. The beneficiary has beneficial interest.

So, as clarification: on an Interest on Trust (IOTA) or a Attorney Trust account, would the attorney or law firm be the benificary for CTR purposes or would the client(s)?

I repeat. Both. Complete a section A entry for the law firm or attorney, and another Section A entry for the attorney's client.

And don't let the attorney claim "attorney-client privilege" here. This isn't a court of law and it's not testimony. It's a federal regulation and an attorney who refuses the information might be liable for causing a financial institution to file an inaccurate or incomplete CTR.

Thank you. I was having someone here still doubt me and wanted more clarification. I appreciate your help.

See Admin Ruling 89-5, scenario #3.

We're having a problem where an individual who has funds in an attorney trust account is cashing checks drawn on the account at different branch locations for which the totals are going over $10,000 when aggregated. He's not a customer, so we do not have any information for him on file, and because none of the individual transactions are over $10,000, the tellers are not getting his information for us to complete the CTR accurately. Can we ask the law firm to provide us with the missing information?

You can and should ask, but wait until you have seen all of the checks before you call the law firm.

There is very little chance they will even give you contact information, let alone the information you need to fill out the form. Because it's based on multiple transactions, you will be able to indicate on the CTR why you do not have the identifying information. However, if the checks are in sequence or appear to have all been written on the same day, you've got to wonder why they did not just write him a single check. Ask.

Combine the number of checks drawn on the same account with the fact that multiple offices were involved and the air fills with the aroma of structuring.