Regulatory Alerts1988-08-02
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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
Financial institutions must file a Currency Transaction Report (CTR) on Form 4789 for currency received by an armored car service from the financial institution's customer, even if the financial institution never physically receives the cash. This duty arises when the armored car service acts as an agent, collecting, transporting, and processing the receipts. If multiple transactions exceed $10,000, financial institutions must aggregate them and ensure their agent obtains all necessary information and identification to complete the CTR.
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