During a BSA review, I questioned bank personnel regarding some CTRs that were filed for a particular commercial customer. This commercial customer makes deposits everyday and they are always made by the same company representative. Our institution generates a daily report that shows the aggregate cash transactions for each business day. Therefore, if a teller did not complete a CTR at the time of the transaction, the BSA officer would file a CTR as appropriate.

In those instances in which the same company representative is coming in, the teller generally does not verify their identity (e.g., driver's license). However, that information is detailed on the CTR from information gathered initially. My gut tells me that we should not be copying that information. However, I am wondering if you all would require the same person to show ID every single day. I know that there is an option for "Other" under method used to verify identity, but I am assuming personally know to me will not fly. Any suggestions ???

I filed tens of thousands of CTRs following the exact procedure you described. Just because you don't require the runner to whip out a driver's license every day does NOT mean you haven't used a govt. ID to verify identity. You DID use one--just on an earlier date. Large cash deposits that are this regular sound more like a Phase I customer than someone who should be reported daily. Is the customer exemptable?

We keep a log for those recurring customers, that has their DLs, soc sec #, address, position and DOB(along with account name & number).
They are happy that we don't have to bother them all of the time. They just say: "It's already in the log", the teller verifies it and they are on their way.
Just make sure that the log is kept secure during the day and locked up at night (Privacy).

It seems to work for us.

Much like the CIP rules, we follow the belief that if you have verified and documented the identification in the past and are comfortable that you know the true identity of the customer in question, there is no need to physically check the ID every time you file. The information is taken from past records (signature cards, etc.) just as it would be if the filing were the result of multiple transactions that were discovered through report reviews.

It is not unusual at all for branches to keep prefilled CTR's for certain customers, and add only the variable (transaction) information when needed. I don't see anything wrong with your practices in this case. The only two suggestions I would offer are:
1- Should a different person bring the deposits in for this company, have the branch collect the identifying information of that person, so you have it on file for CTR filing.
2- Consider exempting this customer. If the business is eligible, and the transaction volume warrants exemption, it will likely save you alot of work in the long run.

These customers are not exemptable (they are casinos).

Is is safe for large sums of cash to walk from the casino to your bank, or should the casino be using an armored carrier to deliver the deposits?

We have Vertex (JHA) teller system, it stores all the customer information collected on "Work with Person" files. The teller simply selects the 'transactor' or creates a new one if needed. We use the same information over & over again for benefactors and transactors. The instructions on the CTR say 'acceptable id information obtained previously and maintained in the financial institution's records may be used'. It gives an example of using ID information recorded on a signature card. I don't see how this is any different.