Often the total amount of the multiple checks brought in to the Bank by Customer 1during a business day to be cashed for this reason exceeds $10,000, thereby requiring the filing ofa CTR. Some of those checks will be for$10,000 or less others may exceed $10,000, depending upon the purchase price of the catch ineach case. Question 1-Completion of Section A of CTRīecause Customer 1 purchases seafood from a number of boats, it often cashes several checks,endorsed back to it by the boat captains, on the same day. The Bank believes that Customer 1uses the currency received when the check is cashed to pay the seafood supplier, ultimately, incurrency.Ĭustomers 2 and 3 are also seafood processing companies that are customers of the Bank.Customers 2 and 3, like Customer 1, engage in the transactions described above to pay seafoodsuppliers for seafood. The captain, in turn, endorses the check back to Customer 1,who then sends an employee to the Bank to cash the check. Customer 1 is a seafood processing company.When it purchases seafood from a shrimpboat captain (or similar seafood supplier boat business),it customarily writes a check for the amount of the purchase price, drawn on Customer 1’saccount at the Bank, to the captain. We understand the relevant facts to be as follows. Our conversations make clear that the Bank supports both the spirit and intent of the BankSecrecy Act (the "BSA"), and we appreciate the diligence shown by you and your colleagues inseeking to confirm how to properly comply with the BSA. Your question was originallyraised in a letter dated August 16, 2000, which was forwarded to the Financial CrimesEnforcement Network (“FinCEN”).1 There have also been follow-up conversations with myoffice. You have asked how (the "Bank") should properly report certain currency transactionson Form 4789 (a "CTR") in the circumstances described below.
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