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Latest Operations - Currency Transaction Reporting Topics

Filing CTR-Round Up to Next Dollar?

09/19/2021

I received a cash deposit for $15,010.45, and of course, had to file a CTR. I filed it for $15,011, but my BSA officer said it should have only been for $15,010. I thought we were supposed to round up to the next dollar, which is correct? By the way, that was the only cash that this customer brought in for the day.

Certificate of Deposit and "Negotiable Instrument"

07/18/2021

A CTR filing is required for a customer for a certificate of deposit made using a $15,000 cash brought in. Would it fall under "negotiable instrument"? The customer also wanted a copy of her statements. She gave $2 cash for the fee, would this fall under "payment"? Need clarification since our auditor did not consider certificate of deposit purchased a negotiable instrument.

CTRs and structuring

04/11/2021

Can our customer be considered to be structuring under our cash rule of $7500? In other words, we gather info on the customer at $7500 in case of a multiple transaction. She has been depositing several times in amounts of $7400 in cash.

CTR Completion Updates- Multiple DBAs

04/11/2021

After watching the Top Gun conference pertaining to CTR completion updates, my collegues and I were discussing how we are doing CTR’s with multiple dba’s. Today the system adds both of the entities under one Part 1 of the CTR with a semi colon separating them. Now we understand if we say we have already implemented the ruling then we need to a separate Part 1 for each of the dba’s? This will be a lot of manual work and just want to make sure we understand the update correctly.

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Use of Nicknames

01/12/2025

How do other banks handle situations where you have an individual who goes by a "preferred name" such as Lillian when their legal name is Lawrence? There is no legal name, identification or SSN change to show as evidence of identity but their place of business is making checks payable to the preferred name as well as their family members. My thing is - how do we know that these checks belong to Lawrence? It could possibly be a family members check.

A Holding Account for Seized Funds

01/05/2025

I am inquiring about opening an account for local police department. They are needing a non-interest bearing account to hold money in that has been seized. The final disposition will be decided by the courts. Is it possible to open a non-interest account and if so how or what do they need to do in order to obtain this?

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