Regulatory Alerts1989-12-21
Added · Updated
FIN-1989-R005: Fulfilling the Requirement to Furnish Information About the Person on Whose Behalf a Reportable Currency Transaction is Conducted
Financial institutions must file complete and accurate Currency Transaction Reports that include identifying information about the person on whose behalf a transaction is conducted. Institutions may rely on existing records to identify the real party in interest only if strong know-your-customer policies satisfy them of the true identity; otherwise, they must ask the person conducting the transaction whether they are acting for themselves or another. The ruling illustrates this obligation through five scenarios involving individual deposits, wire transfers, trust account funds, traveler's check purchases, and corporate deposits by employees.