Regulatory Alerts2009-07-02
Added
Treatment of Deposits by Armored Cars for Currency Transaction Report Purposes
FinCEN rules that when unrelated companies contract directly with an armored car service to make deposits at a bank, the armored car acts as the companies' agent rather than the bank's. If the total currency delivered exceeds $10,000, the bank must file a single Currency Transaction Report, checking boxes for multiple persons and multiple transactions, and completing Section A for each distinct company. The bank must also provide available information about the armored car employee in Section B and aggregate these deposits with other transactions on behalf of the same customer to ensure compliance with the $10,000 threshold.
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