![]() Further, the accounts affectedby the deposit (even if those accounts are not held at Bank B) should be listed below Box 35 andthe phrase “Affiliate transaction(s)” should be written in below Box 36. In addition, the accountsaffected by the deposit should be listed below Box 35 (“Account Number(s) Affected (if any):”)and the phrase “Affiliate Transaction(s)” should be written in below Box 36 (“Other (specify):”).Conversely, if Bank B chooses to file a CTR with respect to the $12,000 deposit, then Bank Bshould fill out Part III of the CTR form with its own information. ![]() If Bank A files a CTR with respect to the customer’s $12,000 deposit, then Bank Ashould fill out Part III of the CTR form with its own information. Thus,for example, Bank A would not need to file a CTR with respect to the customer’s $12,000 cashdeposit so long as it knows for a fact that Bank B filed a CTR with respect to that transaction,and vice-versa.2 The customer’s cash deposit also can be said tooccur “by, through, or to” Bank A, because the cash deposit is conducted at one of its agents.Thus, both Bank A and Bank B are technically required to file a CTR 1 however, to avoidunnecessary duplicative reporting, FinCEN would require that only one report actually be filed(in the manner set forth in the following paragraph) with respect to the same transaction. 31 CFR 103.11(n).Īccording to the facts outlined above, the customer’s cash deposit occurs “by, through,or to” Bank B, because Bank B is the financial institution that physically receives the cash.Thus, Bank B has an obligation to file a CTR. įor purposes of the CTR requirement, a “financial institution” includes a bank, as well as anyagent of a bank. If the bank that holds the customer’s account is responsible for filing the CTR, must the bankalso aggregate the customer’s transactions made through its agent bank even though thetransactions made through the agent are done manually and not through the bank holding theaccount electronic system in conformity with § 103.22(c)(2) aggregation rules?Ī financial institution’s obligation to file a CTR is described in 31 CFR 103.22(b), whichprovides that:Įach financial institution other than a casino shall file a report of each deposit,withdrawal, exchange of currency or other payment or transfer, by, through, or to suchfinancial institution which involves a transaction in currency of more than $10,000. Which bank is responsible for filing the CTR, the bank receiving the cash, the bank thatmaintains the account and receives the cash deposit slip, or both banks?Ģ. You then ask the following two questions:ġ. Your letter correctly acknowledges that the cash deposit of $12,000 by Customer X mustbe reported on a CTR. The two banks settle through an internal account procedure without any physicaltransfer of cash between the banks. Bank A credits the customer’s account in the amount of the cashdeposit. Pursuant to an agency agreementbetween the banks, Bank B processes the cash deposit and sends the appropriate transactioninformation to Bank A. The customer makes a cash deposit of$12,000 at Bank B for credit to his account at Bank A. A customermaintains an account at Bank A, but not at Bank B. In that letter, you requested a ruling on theapplication of the rules relating to the filing of a currency transaction report (“CTR”), asauthorized under the Bank Secrecy Act and its implementing regulations, to the facts outlinedbelow.īank A and Bank B are subsidiaries of the same bank holding company. This responds to your letter dated February 25, 2000, on behalf (the “Bank”), to theFinancial Crimes Enforcement Network (“FinCEN”).
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