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8000 - Miscellaneous Statutes and Regulations
{{10-31-02 p.8516.18-B}}
Appendix A to Part 103Administrative Rulings
88--1 (June 22, 1988)
Issue
What action should a financial institution take when it believes
that it is being misused by persons who are intentionally structuring
transactions to evade the reporting requirement or engaging in
transactions that may involve illegal activity such as drug
trafficking, tax evasion or money laundering?
Facts
A teller at X State Bank notices that the same person comes into the
bank each day and purchases, with cash, between $9,000 and $9,900 in
cashier's checks. Even when aggregated, these purchases never exceed
$10,000 during any one business day. The teller also notices that this
person tries to go to different tellers for each transaction and is
very reluctant to provide information about his frequent transactions
or other information such as name, address, etc. Likewise, the payees
on these cashier's checks all have common names such as "John
Smith" or "Mary Jones." The teller informs the bank's
compliance officer that she believes that this person is structuring
his transactions in order to evade the reporting requirements under the
Bank Secrecy Act. X State Bank wants to know what actions it should
take in this situation or in any other situation where a transaction or
a person conducting a transaction appears suspicious.
Law and Analysis
As it appears that the person may be intentionally structuring the
transactions to evade the Bank Secrecy Act reporting requirements, X
State Bank should immediately telephone the local office of the
Internal Revenue Service ("IRS") and speak to a Special Agent in
the IRS Criminal Investigation Division, or should call
1--800--BSA--CTRS, where his call will be referred to a Special Agent.
Any information provided to the IRS should be given within the
confines of § 1103(c) of the Right to Financial Privacy Act.
12 U.S.C. 3401--3422.
Section 1103(c) of that Act
permits a financial institution to notify a government authority of
information relevant to a possible violation of any statute or
regulation. Such information may consist of the names of any
individuals or corporate entities involved in the suspicious
transactions; account numbers; home and business addresses; social
security numbers; type of account; interest paid on account; location
of the branch or office where the suspicious transaction occurred; a
specification of the offense that the financial institution believes
has been committed; and a description of the activities giving rise to
the bank's suspicion. S. Rep. 99--433, 99th Cong., 2d Sess., pp.
15--16.
Additionally, the bank may be required, by the federal regulatory
agency which supervises it, to submit a criminal referral form. Thus,
the bank should check with its regulatory agency to determine whether a
referral form should be submitted.
Lastly, under the facts as described above, X State Bank is not
required to file a Currency Transaction Report ("CTR") because
the currency transaction (i.e. purchase of cashier's checks) did not
exceed $10,000 during one business day. If the bank had found that on a
particular day the person had in fact used a total of more than $10,000
in currency to purchase cashier's checks, but had each individual
cashier's check made out in amounts of less than $10,000, the bank is
obligated to file a CTR, and should follow the other steps described
above.
Holding
If X State Bank notices that a person may be misusing it by
intentionally structuring transactions to evade the BSA reporting
requirements or engaging in transactions that may involve other illegal
activity, the bank should telephone the local office of the
InternalRevenue Service, Criminal Investigation Division, and report
that information to a Special Agent, or should call 1--800--BSA--CTRS.
In addition, the Federal regulatory agency which supervises X State
Bank may require the bank to submit a criminal referral form. All
disclosures to the Government should be made in accordance with the
provisions of the Right to Financial Privacy Act.
88--2 (June 22, 1988)
Issue
{{10-31-02 p.8516.18-C}}
When, if ever, should a bank file a CMIR on behalf of its customer,
when the customer is importing or exporting more than $10,000 in
currency or monetary instruments?
Facts
A customer walks into B National Bank ("B") with $15,000 in
cash for deposit into her account. As is required, the bank teller
begins to fill out a Currency Transaction Report ("CTR", IRS Form
4789) in order to report a transaction in currency of more than
$10,000. While the teller is filling out the CTR, the customer mentions
to the teller that she has just received the money in a letter from a
relative in France. Should the teller also file a CMIR, either on the
customer's behalf or on the bank's behalf?
Law and Analysis
B National Bank should not file a CMIR when a customer deposits
currency in excess of $10,000 into her account, even if the bank has
knowledge that the customer received the currency from a place outside
the United States. 31 CFR 103.23 requires that a CMIR be filed by
anyone who transports, mails, ships or receives, or attempts, causes or
attempts to cause the transportation, mailing, shipping or receiving of
currency or monetary instruments in excess of $10,000, from or to a
place outside the United States. The term "monetary instruments"
includes currency and instruments such as negotiable instruments
endorsed without restriction. See
31 CFR 103.11(k).
The obligation to file the CMIR is solely on the person who
transports, mails, ships or receives, or causes or attempts to
transport, mail, ship or receive. No other person is under any
obligation to file a CMIR. Thus, if a customer walks into the bank and
declares that he or she has received or transported currency in an
aggregate amount exceeding $10,000 from a place outside the United
States and wishes to deposit the currency into his or her account, the
bank is under no obligation to file a CMIR on the customer's behalf.
Likewise, because the bank itself did not receive the money from a
customer outside the United States, it has no obligation to file a CMIR
on its own behalf. The same holds true if a customer declares his
intent to transport currency or monetary instruments in excess of
$10,000 to a place outside the United States.
However, the bank is strongly encouraged to inform the customer of
the CMIR reporting requirement. If the bank has knowledge that the
customer is aware of the CMIR reporting requirement, but is
nevertheless disregarding the requirement or if information about the
transaction is otherwise suspicious, the bank should contact the local
office of the U.S. Customs Service or 1--800--BE ALERT. The United
States Customs Service has been delegated authority by the Assistant
Secretary (Enforcement) to investigate criminal violations of
31 CFR 103.23. See
31 CFR 103.36(c)(1).
Any information provided to Customs should be given within the
confines of section 1103(c)
of the Right to Financial Privacy Act, 12 U.S.C. 3401--3422. Section
1103(c) permits a financial institution to notify a government
authority of information relevant to a possible violation of any
statute or regulation. Such information may consist of the name
(including those of corporate entities) of any individual involved in
the suspicious transaction; account numbers; home and business
addresses; social security numbers; type of account;
interest
{{4-30-02 p.8517}}paid on account; location of branch where the suspicious
transaction occurred; a specification of the offense that the financial
institution believes has been committed; and a description of the
activities giving rise to the bank's suspicions. See S. Rep.
99--433, 99th Cong., 2nd Sess., pp. 15--16. Therefore, under the facts
above, the teller need only file a CTR for the deposit of the
customer's $15,000 in currency.
A previous interpretation of § 103.23(b) by Treasury held that if
a bank received currency or monetary instruments over the counter from
a person who may have transported them into the United States, and
knows that such items have been transported into the country, it must
file a report on Form 4790 if a complete and truthful report has not
been filed by the customer. See 31 CFR 103 appendix,
§ 103.23, interpretation 2, at 364 (1987). This ruling hereby
supersedes that interpretation.
Holding
A bank should not file a CMIR when a customer deposits
currency or monetary instruments in excess of $10,000 into her account
even if the bank has knowledge that the currency or monetary
instruments were received or transported from a place outside the
United States. 31 CFR 103.23. The same is true if the bank has
knowledge that the customer intends to transport the currency or
monetary instruments to a place outside the United States. However, the
bank is required to file a CTR if it received in excess of $10,000 in
cash from its customer, and is strongly encouraged to inform the
customer of the CMIR requirements. In addition, if the bank has
knowledge that the customer is aware of the CMIR reporting requirement
and is nevertheless planning to disregard it or if the transaction is
otherwise suspicious, the bank should notify the local office of the
United States Customs Service (or 1--800--Be Alert) of the
suspicious transaction. Such notice should be made within the confines
of the Right to Financial Privacy Act,
12 U.S.C. 3403(c).
88--3 (June 22, 1988)
Issue
Whether a bank may exempt "cash-back" transactions of a
customer whose primary business is of a type that may be exempted
either unilaterally by the bank or pursuant to additional authority
granted by the IRS.
Facts
The ABC Grocery ("ABC"), a retail grocery store, has an
account at the X State Bank for its daily deposits of currency. Because
ABC regularly and frequently deposits amounts ranging from $20,000 to
$30,000, the bank has properly granted ABC an exemption for daily
deposits up to a limit of $30,000.
Recently, ABC began providing its customers with a check-cashing
service as an adjunct to its primary business of selling groceries.
ABC's primary business still consists of the sale of groceries.
However, the unexpectedly heavy demand for ABC's check-cashing service
has required ABC to maintain a substantially greater quantity of cash
in the store than was necessary for the grocery business in the past.
To facilitate the operations of its check-cashing service, ABC is
presenting the bank with large numbers of checks in "cash-back"
transactions, rather than depositing the checks into its account and
withdrawing cash from that account. X State Bank has just been
presented with a "cash-back" transaction wherein an employee of
ABC is exchanging $15,000 worth of checks for cash. How should the bank
treat this transaction?
Law and Analysis
A "cash back" transaction is one where one or more
checks or other monetary instruments are presented in exchange for cash
or a portion of the checks or monetary instruments are deposited while
the remainder is exchanged for cash. "Cash back" transactions can
never be exempted from the Bank Secrecy Act reporting requirements.
Thus, the bank must file a Currency Transaction Report on IRS Form 4789
reporting this $15,000 "cash back" transaction, even though the
customer's account has been granted an exemption for daily deposits of
up to $30,000. This is because
§ 103.22(b)(i) permits a
bank to exempt only "(d)eposits or withdrawals of currency
from an existing account by an established depositor who is a
United States resident and operates a retail type of business in
the United States" (emphasis added). As "cash-back"
transactions do not constitute either a
{{4-30-02 p.8518}}"deposit or withdrawal of currency" within the meaning of
the regulations, the bank must report on a CTR any "cash-back"
transaction that results in the transfer of more than $10,000 in
currency to a customer during a single banking day, regardless of
whether the customer has properly been granted an exemption for its
deposits or withdrawals.
Moreover, because "cash back" transactions are never
exemptible, the bank may not unilaterally exempt "cash-back"
transactions by ABC, or seek additional authority from the IRS to grant
a special exemption for ABC's "cash-back" transactions. Instead,
the bank must report ABC's "cash back" transaction on a CTR,
listing it as a $15,000 "check cashed" transaction.
Holding
A bank may never grant a unilateral exemption, or obtain additional
authority from the IRS to grant a special exemption to the
"cash-back" transactions of a customer. A "cash back"
transaction is one where one or more checks or other monetary
instruments are presented in exchange for cash or a portion of the
checks or monetary instruments are deposited while the remainder is
exchanged for cash. If a bank handles a "cash-back" transaction
that results in the transfer of more than $10,000 to a customer during
a single banking day, it must report that transaction on IRS Form 4789,
the Currency Transaction Report, as a "check cashed" transaction,
regardless of whether the customer has been properly granted an
exemption for daily deposits or withdrawals.
88--4 (August 2, 1988)
Issue
If a bank has exempted a single account of a customer into which
multiple establishments of that customer make deposits, must the bank
list all of the establishments on its exemption list or may the bank
list only the § 103.22(f) information of the customer's headquarters
or its principal business establishment on its exemption list?
Facts
A fast food company operates a chain of fast-food restaurants in
several states. In New York, the company has established a single
deposit account at Bank A, into which all of the company's
establishments in that area make deposits. In Connecticut, the company
has established ten bank accounts at Bank B; each of the company's ten
establishments in Connecticut have been assigned a separate account
into which it makes deposits. Banks A and B have properly exempted the
company's accounts, but now seek guidance on the manner in which they
should add these accounts to their exemption lists. All of the
company's establishments use the same taxpayer identification number
("TIN").
Law and Analysis
Under the regulations, the bank must keep "in a centralized
list," § 103.22(f)
information for "each depositor that has engaged in currency
transactions which have not been reported because of (an) exemption
* * *" However, where all of the company's establishments deposit
into one exempt account as at Bank A, above, the bank need only
maintain § 103.22(f) information on its list for the customer's
corporate headquarters or the principal establishment that obtained the
exemption. The bank may, but is not required to, list identifying
information for all of the customers' establishments depositing into
the one account. If the bank chooses to list only the information for
the customer's headquarters or principal establishment, it should
briefly note that on the exemption list and should ensure that the
individual addresses for each establishment are readily available upon
request. Where each of the company's establishments deposit into
separate exempt accounts as at Bank B, the bank must maintain separate
§ 103.22(f) information on the exemption list for each establishment.
Under § 103.22(b)(2) (i), (ii), and (iv) and § 103.22(e)
of the regulation, a bank can only grant an exemption for "an
existing account (of) an established depositor who is a United States
resident." Under these provisions, therefore, the bank can only
grant an exemption for an existing individual account, not for an
individual customer or group of accounts. Thus, if a customer has a
separate account for each of its business establishments, the bank must
consider each account for a separate exemption. If the bank grants
exemptions for more than
{{4-30-02 p.8519}}one
account, it should prepare a separate exemption statement and establish
a separate dollar limit for each account.
Once an exemption has been granted for an account, § 103.22(f)
requires the bank to maintain a centralized exemption list that
includes the name, address, business, types of transactions exempted,
the dollar limit of the exemption, taxpayer identification number, and
account number of the customers whose accounts have been exempted.
Holding
Under 31 CFR 103.22, when a bank has exempted a single account of a
customer into which more than one of the customer's establishments make
deposits, the bank may include the name, address, business, type of
transactions exempted, the dollar limit of the exemption, taxpayer
identification number, and account number ("§ 103.22(f)
information'') of either the customer's headquarters or the principal
business establishment, or it may separately list § 103.22(f)
information for each of the establishments using that account. If the
bank chooses to list only the information for the customer's
headquarters or principal establishment, it should briefly note that
fact on the exemption list, and it should ensure that the individual
addresses of those establishments not on the list are readily available
upon request. If a bank has granted separate exemptions to several
accounts, each of which is used by a single establishment of the same
customer, the bank must include on its exemption list § 103.22(f)
information for each of those establishments. Previous Treasury
correspondence or interpretations contrary to this policy are hereby
rescinded.
88--5 (August 2, 1988)
Issue
Does a financial institution have a duty to file a CTR on currency
transactions where the financial institution never physically receives
the cash because it uses an armored car service to collect, transport
and process its customer's cash receipts?
Facts
X State Bank (the "Bank") and Acme Armored Car Service
("Acme") have entered into a contract which provides for Acme to
collect, transport and process revenues received from Bank customers:
Each day, Acme picks up cash, checks, and deposit tickets from
Little Z, a non-exempt customer of the Bank. Recently, receipts of cash
from Little Z have exceeded $10,000. Acme delivers the checks and
deposit tickets to the Bank where they are processed and Little Z's
account is credited. All cash collected, however, is taken by Acme to
its central office where it is counted and processed. The cash is then
delivered by Acme to the Federal Reserve bank for deposit into the
Bank's account. Must the Bank file a CTR to report a receipt of cash in
excess of $10,000 by Acme from Little Z?
Law and Analysis
Yes. Since Acme is receiving cash in excess of $10,000 on behalf of
the Bank, the Bank must file a CTR in order to report these
transactions.
Section 103.22(a)(1) requires "(e)ach financial institution
* * * [to] file a report of each deposit, withdrawal, exchange of
currency or other payment or transfer, by, through or to such financial
institution which involves a transaction in currency of more than
$10,000." Section
103.11(a) and (g) defines "Bank" and "Financial
Institution" to include agents of those banks and financial
institutions.
Under the facts presented, Acme is acting as an agent of the Bank.
This is because Acme and the Bank have a contractual relationship
whereby the Bank has authorized Acme to pick up, transport and process
Little Z's receipts on behalf of the Bank. The Federal Reserve Bank's
acceptance of deposits from Acme into the Bank's account at the Fed, is
additional evidence of the agency relationship between the Bank and
Acme.
Therefore, when Acme receives currency in excess of $10,000 from
Little Z, the Bank must report that transaction on Form 4789. Likewise,
if Acme receives currency from Little Z in multiple
transactions, § 103.22(a)(1) requires the Bank to aggregate these
transactions and file a single CTR for the total amount of currency
received by Acme, if the Bank has knowledge of these multiple
transactions. Knowledge by the Bank's agent, i.e., Acme, that the
currency was received in multiple transactions, is attributable to the
Bank.
{{4-30-02 p.8520}}The
Bank must assure that Acme, as its agent, obtains all the information
and identification necessary to complete the CTR.
Holding
Financial institutions must file a CTR for the currency received by
an armored car service from the financial institution's customer when
the armored car service physically receives the cash from the customer,
transports it and processes the receipts, even though the currency may
never physically be received by the financial institution. This is
because the armored car service is acting as an agent of the financial
institution.
89-1 (January 12, 1989)
Issue
Under section 103.22 of
the BSA regulations, may a bank unilaterally grant one exemption or
establish a single dollar exemption limit for a group of existing
accounts of the same customer? If not, may a bank obtain additional
authority from the IRS to grant a single exemption for a group of
exemptible accounts belonging to the same customer?
Facts
ABC Inc. ("ABC"), with TIN 12-3456789, owns five fast food
restaurants. Each restaurant has its own account at the X State Bank
and each restaurant routinely deposits less than $10,000 into its
individual account. However, when the deposits into these five accounts
are aggregated they regularly and frequently exceed $10,000.
Accordingly, the bank prepares and files one CTR for ABC Inc., on each
business day that ABC's aggregated currency transactions exceed
$10,000. X State Bank wants to know whether it can unilaterally exempt
these five accounts having the same TIN, and, if not, whether it can
obtain additional authority from the IRS to grant a single exemption to
the group of five accounts belonging to ABC.
Law and Analysis
Under section
103.22(b)(2)(i) and (ii) of the Bank Secrecy Act ("BSA")
regulations, 31 C.F.R. Part 103, only an individual account of a
customer may be unilaterally exempted from the currency transaction
reporting provisions. The bank may not unilaterally grant one exemption
or establish a single dollar exemption limit or multiple accounts of
the same customer. This is because section 103.22(b)(2)(i) and
103.22(b)(2)(ii) of the BSA regulations only permit a bank to
unilaterally exempt "[d]eposits or withdrawals of currency from an
existing account by an established depositor who
is a United States resident and operates a retail type of business in
the United States." 31 C.F.R. 103.22(b)(2)(i) and (ii).
Section 103.22(e) of the BSA regulations provides, however, that
"[a] bank may apply to the . . . [IRS] for additional
authority to grant exemptions to the reporting requirements not
otherwise permitted under paragraph (b) of this section ...." 31
C.F.R. 103.22(e). Therefore, under this authority, and at the request
of a bank, the IRS may, in its discretion, grant the requesting bank
additional authority to exempt a group of accounts when the following
conditions are met:
(1) Each of the accounts in the group is owned by the same person
and has the same taxpayer identification number.
(2) The deposits or withdrawals into each account are made by a
customer that operates a business that may be either unilaterally or
specially exemptible and each account meets the other exemption
criteria (except for the dollar amount).
(3) Currency transactions for each account individually do not
exceed $10,000 on a regular and frequent basis.
(4) Aggregated currency transactions for all accounts included in
the group regularly and frequently exceed $10,000.
If a bank determines that an exemption would be appropriate in a
situation involving a group of accounts belonging to a single customer,
it must apply to the IRS for authority to grant one special exemption
covering the accounts in question. As with all requests for special
exemptions, any request for additional authority to grant a special
exemption must be made in writing and accompanied by a statement of the
circumstances that warrant
{{4-30-02 p.8521}}special exemption treatment and a copy of the statement signed by
the customer as required by section 103.22(d). 31 C.F.R. 103.22(d).
Additional authority to grant a special exemption for a group of
accounts must be obtained from the IRS regardless of whether the
businesses may be unilaterally exempted under 103.22(b)(2), because the
exemption, if granted, would apply to a group of existing
accounts as opposed to an individual existing account. 31
C.F.R. § 103.22(b)(2).
Also, if any one of a given customer's accounts has regular and
frequent currency transactions which exceed $10,000, that account
may not be included in the group exemption. This is because
the bank may, as provided by section 103.22(b)(2), either unilaterally
exempt that account or obtain authority from the IRS to grant a special
exemption for that account if it meets the other criteria for
exemption. Thus, only accounts of exemptible businesses which do not
have regular and frequent ( e.g., daily, weekly or twice a
month) currency transactions in excess of $10,000 may be eligible for a
group exemption.
The intention of this special exemption is to permit banks to exempt
the accounts of established customers, such as the ABC Inc. restaurants
described above, which are owned by the same person and have the same
TIN but which individually do not have sufficient currency deposit or
withdrawal activity that regularly and frequently exceed $10,000.
Holding
If X State Bank determines that an exemption would be appropriate
for ABC Inc., it must apply to the IRS for authority to grant one
special exemption covering ABC's five separate accounts. As with all
requests for special exemptions, ABC's request for additional authority
to grant a special exemption must be made in writing and accompanied by
a statement of the circumstances that warrant special exemption
treatment and a copy of the statement signed by the customer as
required by section 103.22(d). 31
C.F.R. 103.22(d). The IRS may, in its discretion, grant
additional authority to exempt the ABC accounts if: (1) they have the
same taxpayer identification number; (2) they each are for customers
that operate a business that may be either unilaterally or specially
exemptible and each account meets the other exemption criteria (except
for dollar amount); (3) the currency transactions for each account
individually do not exceed $10,000 on a regular and frequent basis; but
(4) when aggregated the currency transactions for all the accounts
regularly and frequently do exceed $10,000.
89--2 (June 21, 1989)
Issue
When a customer has established bank accounts for each of several
establishments that it owns, and the bank has exempted one or more of
those accounts, how does the bank aggregate the customer's currency
transactions?
Facts
X Company ("X") operates two fast-food restaurants and a
wholesale food business. X has opened separate bank accounts at the A
National Bank (the "bank") for each of its two restaurants,
account numbers 1 and 2 respectively. Each of these accounts has been
properly exempted by the bank. Account number 1 has an exemption limit
of $25,000 for deposits, and account number 2 has an exemption limit of
$40,000 for deposits. X also has a third account, account number 3, at
the bank for use in the operation of its wholesale food business. On
occasion, cash deposits of more than $10,000 are made into this third
account. Because these cash deposits are infrequent, the bank cannot
obtain additional authority to grant this account a special exemption.
During the same business day, two $15,000 cash deposits totalling
$30,000 are made into account number 1, a separate cash deposit of
$35,000 is made into account number 2 and a deposit of $9,000 in
currency is made into account number 3 (X's account for its wholesale
food business).
The bank must now determine how to aggregate and report all of these
transactions on a Form 4789, Currency Transaction Report,
("CTR"). Must they aggregate all of the deposits made into
account numbers 1, 2 and 3 and report them on a single CTR?
{{4-30-02 p.8522}}
Law and Analysis
Section 103.22 of the Bank Secrecy Act ("BSA"), 31 CFR Part
103, requires a financial institution to treat multiple currency
transactions "as a single transaction if the financial institution
has knowledge that they are by or on behalf of any person and result in
either cash-in or cash-out totalling more than $10,000 during any one
business day." This means that a financial institution must file a
CTR if it knows that multiple currency transactions involving two or
more accounts have been conducted by or on behalf of the same person
and, those transactions, when aggregated, exceed $10,000. Knowledge, in
this context, means knowledge on the part of a partner, director,
officer or employee of the institution or on the part of any existing
computer or manual system at the institution that permits it to
aggregate transactions.
Thus, if the bank has knowledge of multiple transactions, the bank
should aggregate the transactions in the following manner.
First, the bank should separately review and total all cash-in and
cash-out transactions within each account. Cash-in transactions should
be aggregated with other cash-in transactions and cash-out transactions
should be aggregated with cash-out transactions. Cash-in and cash-out
transactions should not be aggregated together or offset against each
other.
Second, the bank should determine whether the account has an
exemption limit. If the account has an exemption limit, the bank should
determine whether it has been exceeded. If the exemption limit has not
been exceeded, the transactions for the exempted account should not be
aggregated with other transactions.
If the total transactions during the same business day for a
particular account exceed the exemption limit, the total of all of the
transactions for that account should be aggregated with the total
amount of the transactions for other accounts that exceed their
respective exemption limits, with any accounts without exemption
limits, and with transactions conducted by or on behalf of the same
person that do not involve accounts (e.g., purchases of bank checks
with cash) of which the bank has knowledge.
In the example discussed above, all of the transactions have been
conducted "on behalf of" X, as X owns the restaurants and the
wholesale food business. The total $30,000 deposit for account 1
exceeds the $25,000 exemption limit for that account. The $35,000
deposit into account number 2 is less than the $40,000 exemption limit
for that account. Finally, the $9,000 deposit into account number 3,
does not by itself constitute a reportable transaction.
Therefore, under the facts above, the bank should aggregate the
entire $30,000 deposit into account number 1 (not just the amount that
exceeds the exemption limit), with the $9,000 deposit into account
number 3, for a total of $39,000. The bank should not include the
$35,000 deposit into account number 2, as that deposit does not exceed
the exemption limit for that account. Accordingly, the bank should
complete and file a single CTR for $39,000.
If the bank does not have knowledge that multiple currency
transactions have been conducted in these accounts on the same business
day (e.g., because it does not have a system that aggregates among
accounts and the deposits were made by three different individuals at
different times) the bank should file one CTR for $30,000 for account
number 1, as the activity into that account exceeds its exemption
limit.
Holding
When a customer has more than one account and a bank employee has
knowledge that multiple currency transaction have been conducted in the
accounts or the bank has an existing computer or manual system that
permits it to aggregate transactions for multiple accounts, the bank
should aggregate the transactions in the following manner.
First, the bank should aggregate for each account all cash-in or
cash-out transactions conducted during one business day. If the account
has an exemption limit, the bank should determine whether the exemption
limit of that account has been exceeded. If the exemption limit has
not been exceeded, the total of the transactions for that particular
account does not have to be aggregated with other transactions. If the
total transactions
{{4-30-02 p.8523}}during
the same business day for a particular account exceed the exemption
limit, however, the total of all of the transactions for that account
should be aggregated with any total from other accounts that exceed
their respective exemption limits, with any accounts without exemption
limits, and with any reportable transactions conducted by or on behalf
of the customer not involving accounts (e.g., purchases of bank checks
or "cash back" transactions) of which the bank has knowledge. The
bank should then file a CTR for the aggregated amount.
89--5 (December 21, 1989)
Issue
How does a financial institution fulfill the requirement that it
furnish information about the person on whose behalf a reportable
currency transaction is being conducted?
Facts
No. 1
Linda Scott has had an account relationship with the Bank for 15
years. Ms. Scott enters the bank and deposits $15,000 in cash into her
personal checking account. The bank knows that Ms. Scott is an artist
who on occasions exhibits and sells her art work and that her art work
currently is on exhibit at the local gallery. The bank further knows
that cash deposits in the amount of $15,000 are commensurate with Ms.
Scott's art sales.
No. 2
Dick Wallace has recently opened a personal account at the Bank.
Although the bank verified his identity when the account was opened,
the bank has no additional information about Mr. Wallace. Mr. Wallace
enters the bank with $18,000 in currency and asks that it be wire
transferred to a bank in a foreign country.
No. 3
Dorothy Green, a partner at a law firm, makes a $50,000 cash deposit
into the firm's trust account. 1
The bank knows that this is a trust account. The $50,000 represents
cash received from three clients.
No. 4
Carlos Gomez enters a Currency Dealer and asks to buy $12,000 in
traveler's checks with cash.
No. 5
Gail Julian, a trusted employee of Q-mart, a large retail chain,
enters the bank three times during one business day and makes three
large cash deposits totalling $48,000 into Q-mart's account. The Bank
knows that Ms. Julian is responsible for making the deposits on behalf
of Q-mart. Q-mart has an exemption limit of $45,000.
Law and Analysis
Under section 103.28 of
the Bank Secrecy Act ("BSA") regulations, 31 C.F.R. Part 103, a
financial institution must report on a Currency Transaction Report
("CTR") the name and address of the individual conducting the
transaction, and the identity, account number, and the social security
or taxpayer identification number of any person on whose behalf the
transaction was conducted. See
31 U.S.C. 5313. "A
participant acting for another person shall make the report as the
agent or bailee of the person and identify the person for whom the
transaction is being made." Identifying information about the person
on whose behalf the transaction is conducted must always be furnished
if the transaction is reportable under the BSA, regardless of whether
the transaction involves an account.
Because the BSA requires financial institutions to file complete and
accurate CTR's, it is the financial institution's responsibility to
ascertain the real party in interest. 31 U.S.C. § 5313. One way that
a financial institution can obtain information about the identity of
the person on whose behalf the transaction is being conducted is to ask
the person conducting the transaction whether he is acting for himself
or on behalf of another person. Only if as a result of strong "know
your customer" or other internal control policies, the financial
institution is satisfied that its records contain information
concerning the true
{{4-30-02 p.8524}}identity of the person on whose behalf the transaction is
conducted, may the financial institution rely on those records to
complete the CTR.
No. 1
Linda Scott, an artist, is a known customer of the bank. The bank is
aware that she is exhibiting her work at a local gallery and that cash
deposits in the amount of $15,000 would not be unusual or inconsistent
with Ms. Scott's business practices. Therefore, if the bank through its
stringent "know your customer" policies is satisfied that the
money being deposited by Ms. Scott into her personal account is for her
benefit, the bank need not ask Ms. Scott whether she is acting on
behalf of someone else.
No. 2
Because Dick Wallace is a new customer of the bank and because the
bank has no additional information about him or his business activity,
the bank should ask Mr. Wallace whether he is acting on his own behalf
or on behalf of someone else. This is particularly true given the
nature of the transaction--a wire transfer with cash for an individual
to a foreign country.
No. 3
Dorothy Green's cash deposit of $50,000 into the law firm's trust
account clearly is being done on behalf of someone else. The bank
should ask Ms. Green to identify the clients on whose behalf the
transaction is being conducted. Because Ms. Green is acting both on
behalf of her employer and the clients, the names of the three clients
and the law firm should be included on the CTR filed by the bank.
No. 4
The currency dealer, having no account relationship with Carlos
Gomez, should ask Mr. Gomez if he is acting on behalf of someone else.
No. 5
Gail Julian is known to the bank as a trusted employee of Q-mart,
who often deposits cash into Q-mart's account. If the bank, through its
strong "know your customer" policies is satisfied that Ms. Julian
makes these deposits on behalf of Q-mart, the bank need not ask her if
she is acting on behalf of someone other than Q-mart.
Holding:
It is the responsibility of a financial institution to file complete
and accurate CTRs. This includes providing identifying information
about the person on whose behalf the transaction is conducted in Part
II of the CTR. One way that a financial institution can obtain
information about the true identity of the person on whose behalf the
transaction is being conducted is to ask the person conducting the
transaction whether he is acting for himself or on behalf of another
person. Only if as a result of strong "know your customer" or
other internal control policies, the financial institution is satisfied
that its records contain the necessary information concerning the true
identity of the person on whose behalf the transaction is being
conducted, may the financial institutions rely on those records in
completing the CTR.
92-1 (November 16, 1992)
Issue
How does a financial institution fulfill the requirement to verify
and record the name and address of an elderly or disabled individual
who conducts a currency transaction in excess of $10,000 or who
purchases certain monetary instruments with currency valued between
$3,000 and $10,000 when he/she does not possess a passport, alien
identification card or other official document, or other document that
is normally acceptable within the banking community as a means of
identification when cashing checks for nondepositors?
Holding
It is the responsibility of a financial institution to file complete
and accurate CTRs and to maintain complete and accurate monetary
instrument logs pursuant to 31
C.F.R. §§ 103.27(d) and
103.29 of the BSA
regulations. It is also the responsibility of a financial institution
to verify and to record the identity of individuals conducting
reportable currency transactions and/or cash purchases of certain
monetary instruments as required by BSA regulations
§§ 103.28 and 103.29.
Only if the financial institution is confident that
{{4-30-02 p.8524.01}}an
elderly or disabled patron is who s/he says s/he is may it complete
these transactions. A financial institution shall use whatever
information it has available, in accordance with its established
policies and procedures, to determine its patron's identity. This
includes review of its internal records for any information on file,
and asking for other forms of identification, including a social
security or medicare/medicaid card along with another document which
contains both the patron's name and address such as an organizational
membership card, voter registration card, utility bill or real estate
tax bill. These forms of identification shall also be identified as
acceptable in the bank's formal written policy and operating procedures
as identification for transactions involving the elderly or the
disabled. Once implemented, the financial institution should permit no
exception to its policy and procedures. In these cases, the financial
institution should record the word "Elderly" or "Disabled"
on the CTR and/or chronological log and the method used to identify the
elderly, or disabled patron such as "Social Security and
(organization) Membership Card only ID."
Law and Analysis
Before concluding a transaction for which a Currency Transaction
Report is required pursuant to 31 C.F.R. § 103.22, a financial
institution must verify and record the name and address of the
individual conducting the transaction. 31 C.F.R. § 103.28.
Verification of the individual's identity must be made by examination
of a document, other than a bank signature card, that is normally
acceptable within the banking community as a means of identification
when cashing checks for nondepositors (e.g., a driver's
license). A bank signature card may be relied upon only if it was
issued after documents establishing the identity of the individual were
examined and a notation of the method and specific information
regarding identification (e.g. state of issuance and
driver's license number) was made on the signature card. In each
instance, the specific identifying information noted above and used to
verify the identity of the individual must be recorded on the CTR. The
notation of "known customer" or "bank signature card on
file" on the CTR is prohibited. 31 C.F.R. § 103.28.
Before issuing or selling bank checks or drafts, cashier's checks,
traveler's checks or money orders to an individual(s), for currency
between $3,000 and $10,000, a financial institution must verify whether
the individual has a deposit account or verify the individual's
identity. 31 C.F.R. § 103.29. Verification may be made by examination
of a signature card or other account record at the financial
institution if the deposit accountholder's name and address were
verified at the time the account was opened, or at any subsequent time,
and that information was recorded on the signature card or record being
examined.
Verification may also be made by examination of a document that
contains the name and address of the purchaser and which is normally
acceptable within the banking community as a means of identification
when cashing checks for nondepositors. In the case of a deposit
accountholder whose identity has not been previously verified, the
financial institution shall record the specific identifying information
on its chronological log (e.g. state of issuance and
driver's license number). In all situations, the financial institution
must record all the appropriate information required by
§ 103.29(a)(1)(i) for deposit account holders or 103.29(a)(2)(i) for
nondeposit account holders.
Certain elderly or disabled patrons do not possess identification
documents that would normally be considered acceptable within the
banking community (e.g., driver's licenses, passports, or
state-issued identification cards). Accordingly, the procedure set
forth below should be followed to fulfill the identification
verification requirements of §§ 103.28 and 103.29.
Financial institutions may accept as appropriate identification a
social security, medicare, medicaid or other insurance card presented
along with another document that contains both the name and address
of the patron (e.g. an organization membership or voter
registration card, utility or real estate tax bill). Such forms of
identification shall be specified in the bank's formal written policy
and operating procedures as acceptable identification for transactions
involving elderly or disabled patrons who do not possess
{{4-30-02 p.8524.02}}identification documents normally considered acceptable within
the banking community for cashing checks for nondepositors.
This procedure may only be applied if the following circumstances
exist. First, the financial institution must establish that the
identification the elderly or disabled patron has is limited to a
social security or medicare/medicaid card plus another document which
contains the patron's name and address. Second, the financial
institution must use whatever information it has available, or policies
and procedures it has in place, to determine the patron's identity. If
the patron is a deposit accountholder, the financial institution should
review its internal records to determine if there is information on
file to verify his/her identity. Only if the financial institution is
confident that the elderly or disabled patron is who s/he says s/he is,
may the transaction be concluded. Failure to identify an elderly or a
disabled customer's identity as required by
31 CFR § 103.28 and as
described herein may result in the imposition of civil and or criminal
penalties. Finally, the financial institution shall establish a formal
written policy and implement operating procedures for processing
reportable currency transactions or recording cash sales of certain
monetary instruments to elderly or disabled patrons who do not have
forms of identification ordinarily considered "acceptable." Once
implemented, the financial institution shall permit no exceptions to
its policy and procedures. In addition, financial institutions are
encouraged to record the elderly or disabled patron's identity and
address as well as the method of identification on a signature card or
other record when it is obtained and verified.
In completing a CTR, if all of the above conditions are satisfied,
the financial institution should enter the words "Elderly" or
"Disabled" and the method used to verify the patron's identity,
such as "Social Security & (organization) Membership Cards Only
ID," in Item 15a.
Similarly, when logging the cash purchase of a monetary
instrument(s), the financial institution shall enter on its
chronological log the words, "Elderly" or "Disabled," and
the method used to verify such patron's identity.
Example
Jesse Fleming, a 75 year old retiree, has been saving $10 bills for
twenty years in order to help pay for his granddaughter's college
education. He enters the Trustworthy National Bank where he has no
account but his granddaughter has a savings account, and presents
$13,000 in $10 bills to the teller. He instructs the teller to deposit
$9,000 into his granddaughter's savings account, and requests a
cashier's check for $4,000 made payable to State University.
Because of poor eyesight, Mr. Fleming no longer drives and does not
possess a valid driver's license. When asked for identification by the
teller he presents a social security card and his retirement
organization membership card that contains his name and address.
Application of Law to Example
In this example, the Trustworthy National Bank must check to
determine if Mr. Fleming's social security and organizational
membership cards are acceptable forms of identification as defined in
the bank's policy and procedures. If so, and the bank is confident that
Mr. Fleming is who he says he is, it may complete the transaction.
Because Mr. Fleming conducted a transaction in currency which exceeded
$10,000 (deposit of $9,000 and purchase of $4,000 monetary instrument),
First National Bank must complete a CTR. It should record information
about Mr. Fleming in Part I of the CTR and in Item 15a record the words
"Elderly--Social Security and (organization) Membership Cards Only
ID." The balance of the CTR must be appropriately completed as
required by §§ 103.22
and 103.27(d). First
National Bank must also record the transaction in its monetary
instrument sales log because it issued to Mr. Fleming a cashier's check
for $4,000 in currency. Mr. Fleming must be listed as the purchaser and
the bank should record on the log the words "Elderly--Social
Security and (organization) Membership Cards Only ID" as the method
used to verify his identity. In addition, because Mr. Fleming is not a
deposit accountholder at First National Bank, the bank is required to
record on the log all the
{{4-30-02 p.8524.03}}information required under § 103.29(a)(2)(i) for cash purchases
of monetary instruments by nondeposit accountholders.
92-2 (November 16, 1992)
Issue
How should a financial institution complete a CTR when multiple
transactions are aggregated and reported on a single form and all or
part of the information called for in the form may not be known?
Holding
Multiple transactions that total in excess of $10,000, or an
established exemption limit, when aggregated must be reported on a CTR
if the financial institution has knowledge that the transactions have
occurred. In many cases, the individual transactions being reported are
each under $10,000, or the exemption limit, and the institution was not
aware at the time of any one of the transactions that a CTR would be
required. Therefore, the identifying information on the person
conducting the transaction was not required to be obtained at the time
the transaction was conducted.
If after a reasonable effort to obtain the information required to
complete items 4 through 15 of the CTR, all or part of such information
is not available, the institution must check item 3d to indicate that
the information is not being provided because the report involves
multiple transactions for which complete information is not available.
The institution must, however, provide as much of the information as is
reasonably available.
All subsections of item 48 on the CTR must be completed to report
the number of transactions involved and the number of locations of the
financial institution and zip codes of those locations where the
transactions were conducted.
Law and Analysis
Sections 103.22(a)(1)
and (c) of the Bank Secrecy Act (BSA) regulations, 31 C.F.R. Part 103,
require a financial institution to file a CTR for each deposit,
withdrawal, exchange of currency, or other payment or transfer, by,
through, or to the financial institution, which involves a transaction
in currency of more than $10,000 or the established exemption limit for
an exempt account. Multiple transactions must be treated as a single
transaction if the financial institution has knowledge that they are
by, or on behalf of, any person and result in either cash in or cash
out of the financial institution totalling more than $10,000 or the
exemption limit during any one business day. Knowledge, in this
context, means knowledge on the part of a partner, director, officer or
employee of the financial institution or on the part of any existing
automated or manual system at the financial institution that permits it
to aggregate transactions.
The purpose of item 3 on the CTR is to indicate why all or part of
the information required in items 4 through 15 is not being provided on
the form. If the reason information is missing is solely because the
transaction(s) occurred through an armored car service, a mail deposit
or shipment, or a night deposit or Automated Teller Machine (ATM), the
financial institution must check either box a, b, or c, as appropriate,
in item 3. CTR instructions state that item 3d is to be checked for
multiple transactions where none of the individual transactions exceeds
$10,000 or the exemption limit and all of the required information
might not be available.
As described in Example No. 5 below, there may be situations where
one transaction among several exceeds the applicable threshold. Item 3d
should be checked whenever multiple transactions are being reported and
all or part of the information necessary to complete items 4 through 15
is not available because at the time of any one of the individual
transactions, a CTR was not required and the financial institution did
not obtain the appropriate information.
When reporting multiple transactions, the financial institution must
complete as many of items 4 through 15 as possible. In the event the
institution learns that more than one person conducted the multiple
transactions being reported, it must check item 2 on the CTR and is
encouraged to make reasonable efforts to obtain and report any
appropriate information on each of the persons in items 4 through 15 on
the front and back of the CTR form, and if necessary, on additional
sheets of paper attached to the report.
{{4-30-02 p.8524.04}}
The purpose of item 48 is to indicate that multiple transactions are
involved in the CTR being filed. Items 48 a, b, and c require
information about the number of transactions being reported and the
number of bank branches and the zip code of each branch where the
transactions took place. If multiple transactions exceeding $10,000 or
an account exemption limit occur at the same time, the financial
institution should treat the transactions in a manner consistent with
its internal transaction posting procedures. For example, if a customer
presents four separate deposits, at the same time, totalling over
$10,000, the institution may report the transactions in item 48a to be
one or four separate transactions. If the transactions are posted as
four separate transactions the financial institution should enter the
number 4 in item 48a and the number 1 in item 48b. If the transactions
are posted as one transaction the institution should enter the number 1
in both 48a and 48b. Reporting the transactions in this manner will
guarantee the integrity of the paper trail being created, that is, the
number of transactions reported on the CTR will be the same as the
number of transactions showing in the institution's records.
These situations should be differentiated from those cases where
separate transactions occur at different times during the same business
day, and which, when aggregated, exceed $10,000 or the exemption limit.
For instance, if the same or another individual conducts two of the
same type of transactions at different times during the same business
day at two different branches of the financial institution on behalf of
the same person, and the institution has knowledge that the
transactions occurred and exceed $10,000 or the exemption limit, then
the financial institution must enter the number 2 in items 48a and 48b.
Examples and Application of Law to Examples
Example No. 1
Dorothy Fishback presents a teller with three cash deposits to the
same account, at the same time, in amounts of $5,000, $6,000, and
$8,500 requesting that the deposits be posted to the account
separately. It is the bank's procedure to post the transactions
separately. A CTR is completed while the customer is at the teller
window.
Application of Law to Example No. 1
A CTR is completed based upon the information obtained at the time
Dorothy Fishback presents the multiple transactions. Item 3d would not
be checked on the CTR because all of the information in items 4 through
15 is being provided contemporaneously with the transaction. As it is
the bank's procedure to post the transactions separately, the number of
transactions reported in item 48a would be 3 and the number of branches
reported in item 48b would be 1. The zip code for the location where
the transactions were conducted would be entered in item 48c.
Example No. 2
Andrew Weiner makes a $7,000 cash deposit to his account at ABC
Federal Savings Bank. Later the same day, Mr. Weiner returns to the
same teller and deposits $5,000 in cash to a different account. At the
time Mr. Weiner makes the second deposit, the teller realizes that the
two deposits exceed $10,000 and prepares a CTR obtaining all of the
necessary identifying information directly from Mr. Weiner.
Application of Law to Example No. 2
Even though the two transactions were conducted at different times
during the same business day, Mr. Weiner conducted both transactions at
the same place and the appropriate identifying information was obtained
by the teller at the time of the second transaction. Item 3d would not
be checked on the CTR. The number of transactions reported in item 48a
must be 2 and the number of branches reported in item 48b would be 1.
The zip code for the location where the transactions took place would
be entered in item 48c.
Example No. 3
Internal auditor Mike Pelzer is reviewing the daily cash
transactions report for People's Bank and notices that five cash
deposits were made the previous day to account #12345. The total of the
deposits is $25,000 and they were made at three different offices of
the bank. Mike researches the account data base and finds that the
account belongs to a
{{4-30-02 p.8524.05}}department store and that the account is exempted for deposits up
to $17,000 per day. Each of the five transactions was under $17,000.
Application of Law to Example No. 3
Having reviewed the report of aggregated transactions, Mike Pelzer
has knowledge that transactions exceeding the account exemption limit
have occurred during a single business day. A CTR must be filed.
People's Bank is encouraged to make a reasonable effort to provide the
information for items 4 through 15 on the CTR. Such efforts could
include a search of the institution's records or a phone call to the
department store to identify the persons that conducted the
transactions. If all of the information is not contained in the
institution's records or otherwise obtained, item 3d must be checked.
The number of transactions reported in item 48a must be 5 and the
number of branches reported in 48b would be 3. The zip codes for the
three locations where the transactions occurred must be entered in item
48c.
Example No. 4
Mrs. Saunders makes a cash withdrawal, for $4,000, from a joint
savings account she owns with her husband. That day her husband, Mr.
Saunders, withdraws $7,000 cash using the same teller. Realizing that
the withdrawals exceed $10,000, the teller obtains identifying
information on Mr. Saunders required to complete a CTR.
Application of Law to Example No. 4
In this case, item 2 on the CTR must be checked because the teller
knows that more than one person conducted the transactions. Information
on Mr. Saunders would appear in Part I and the bank is encouraged to
ask him for, or to check its records for the required identifying
information on Mrs. Saunders. If after taking reasonable efforts to
locate the desired information, all of the required information is not
found on file in the institution's records or is not otherwise
obtained, box 3d must be checked to indicate that all information is
not being provided because multiple transactions are being reported.
Whatever information on Mrs. Saunders is contained in the records of
the institution must be reported in the continuation of Part I on the
back of Form 4789. The number of transactions reported in item 48a must
be 2 and the number of branches reported in item 48b would be 1. The
zip code for the branch where the transactions took place would be
entered in item 48c.
Example No. 5
On another day, Mrs. Saunders makes a deposit of $3,000 cash and no
information required for Part I of the CTR is requested of her. She is
followed later the same day by her husband, Mr. Saunders, who deposits
$12,000 in currency and who provides all data required to complete Part
I for himself.
Application of Law to Example No. 5
Item 2 on the CTR must be checked because the teller knows that more
than one person conducted the transactions. Information on Mr. Saunders
would appear in Part I and the bank is encouraged to ask him for, or to
check its records for the required identifying information on Mrs.
Saunders. If after taking reasonable efforts to locate the desired
information, all of the required information is not found on file in
the institution's records or is not otherwise obtained, box 3d must be
checked to indicate that all information is not being provided because
multiple transactions are being reported. Whatever information on Mrs.
Saunders is contained in the records of the institution must be
reported in the continuation of Part I on the back of Form 4789. The
number of transactions reported in item 48a must be 2 and the number of
branches reported in item 48b would be 1. The zip code for the branch
where the transactions took place would be entered in item 48c.
Example No. 6
A review of First Federal Bank's daily cash transactions report for
a given day indicates several cash deposits to a single account
totaling more than $10,000. Two separate deposits were made in the
night depository at the institution's main office, and two deposits
were conducted at the teller windows of two other branch locations.
Each deposit was under $10,000.
{{4-30-02 p.8524.06}}
Application of Law to Example No. 6
Item 3c should be checked to indicate that identifying information
is not provided because transactions were received through the night
deposit box. If the tellers involved with the two face to face deposits
remember who conducted the transactions, institution records can be
checked for identifying information. If the records contain some of the
information required by items 4 through 15, that information must be
provided, and item 3d must be checked to indicate that some information
is missing because multiple transactions are being reported and the
information was not obtained at the time the transactions were
conducted. Item 48a must indicate 4 transactions and item 48b must
indicate 3 locations. The zip codes of those locations would be
provided in item 48c.
[Codified to 31 C.F.R. Part 103, Appendix A]
[Appendix added at 37 Fed. Reg. 24896, November 23, 1972; amended
at 43 Fed. Reg. 27826, June 27, 1978, effective June 19, 1978; 50 Fed.
Reg. 43692, October 22, 1985, effective November 21, 1985; 53 Fed. Reg.
40064, October 13, 1988, with rulings 88--1, 88--2 and 88--3 effective
June 22, 1988 and rulings 88--4 and 88--5 effective August 2, 1988; 54
Fed. Reg. 21214, May 17, 1989, effective January 12, 1989; 54 Fed. Reg.
30543, July 21, 1989 effective June 21, 1989; 55 Fed. Reg. 1022,
January 11, 1990, effective December 21, 1989; 58 Fed. Reg. 7047,
February 4, 1993, effective November 16, 1992; 67 Fed. Reg. 9876, March
4, 2002]
1This type of account is sometimes called a trust account,
attorney account or special account. It is an account established by an
attorney into which commingled funds of clients maybe deposited. It is
not necessarily a "trust" in the legal sense of the term. Go Back to Text
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