Regulatory Alerts2000-08-31
Added
FinCEN Ruling 2000-1: Guidance on Completing CTR Section A for Transactions on Behalf of Others
Financial institutions must complete Section A of Currency Transaction Reports (CTR) using the original payee's information if a customer cashes double-endorsed checks exceeding $10,000 in aggregate for that payee. When the total amount of checks for a specific original payee exceeds $10,000, the bank must check the multiple persons box and include a separate Section A for that payee, while using the customer's information for checks under the threshold. If a customer refuses to provide necessary information for checks exceeding $10,000, the institution must document its good faith efforts to obtain the data and the reasons for the incompleteness, as failure to provide this explanation may result in the CTR being returned.
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