BSA Reporting of Foreign ATM Deposits

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Question:

Regarding foreign ATM deposits of more than $10,000, we have no way to identify if they were made by cash or check. Is there any responsibility for BSA reporting in these instances?

Answer:

Yes, the ATM host bank knows of the cash deposit and your bank has the customer information. Network rules should provide guidance on reporting cash deposit information to the card-issuing bank. FinCEN issued guidance relating to agency banks that accepted deposits from the customers of another institution. Each institution had CTR-filing responsibility, but FinCEN said they can agree between them who will actually file. That's very much analogous to the interchange deposit question you raise. See FinCEN Ruling 2001-1.

First published on BankersOnline.com 3/22/10