We had a non-customer come in and cash an on us check. The indvidual had a driver's license but claimed to have no SSN. We use Vertex and it requires something in the SSN field so I had them do a CTR on the system using his driver's license number in the SSN field.

Then I got to thinking that maybe we should not have done the transaction at all. Without alien id how do we know he is really an alien and really doesn't have a SSN?

At this point the CTR is non-reportable because it was a check for less than $10,000 (the tellers get a prompt to complete the CTR that is used tracking purposes only).
But I was thinking about next time. If no SSN is obtained for the CTR, and nothing to prove they are an alien, should we not have done the transaction?

Vertex is programmed to deal with the no TIN senario by having a hook in the ID field. If a 'P' for passport or 'A' for Alien Registration is entered in the ID field in the Work with Person screen, and the TIN field is blank, Vertex will print 'NONE' in the TIN field. And yes, it does seem strange that they would have a DL but not a TIN. Makes you wonder.