Regulatory Alerts2013-07-12
Treatment of Armored Car Service Transactions Conducted on Behalf of Financial Institution Customers or Third Parties for Currency Transaction Report Purposes
The Financial Crimes Enforcement Network (FinCEN) issued this administrative ruling to grant an exception to Currency Transaction Report (CTR) requirements for armored car service (ACS) transactions conducted on behalf of financial institution customers or third parties. This relief allows financial institutions to satisfy identification obligations by reporting only the customer and the ACS's corporate information, thereby exempting ACS employees from providing personal identifying details. The ruling supersedes FIN-2009-R002 and requires financial institutions to implement procedures to determine the source of ACS instructions, with full compliance expected by September 30, 2013.
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