Skip to content
 

Wire Transfer - Name on CTR

Answered by: 
John Burnett

Question: 
If a non-customer brings in over $10,000 in cash to wire to a company to purchase equipment, who would be the "person on whose behalf the transaction was completed" on a CTR since the person with the cash would not have the identifying information such as TIN for the company receiving the wire transfer?
Answer: 

It's important to note that the CTR does not ask you to identify who will benefit from the transaction. It asks for the name of the person on whose behalf the transaction is completed. There is a subtle difference. In this case, the person to be identified in section A of part I of the form is the party that is sending the wire (the purchaser of the equipment). If the transaction is being made on behalf of a company, the company is listed in section A and the individual completing the transaction goes in section B. An analogous situation arises if a bundle of cash is brought in by or for a bank customer, to purchase an official check. If you have to complete a CTR because the transaction exceeds the CTR threshold then you list your customer, the purchaser, not the payee on the check.

First published on BankersOnline.com 2/16/09

First published on 02/16/2009

Filed under: 
Security
Filed under security as: 
IT
TIN

Report a problem with this page

Search Topics