Stay compliant when handling cash over $10,000

Before anything else, you'll need a valid government-issued photo ID from the person making the transaction. This is required by BSA rules -- there's no way around it. Here's what to check and record: - **ID type** -- driver's license, passport, state ID, or military ID all work - **ID number and issuing state/country** -- write these down exactly as they appear - **Expiration date** -- if it's expired, you can't proceed with the transaction For existing customers, pull up their profile and confirm the ID on file hasn't expired. If it has, you'll need a fresh one before moving forward. For walk-ins or non-account holders, make a photocopy of their ID -- your branch should have a scanner at the teller line for this. **Tip from experience**: Don't rush this step. A wrong ID number on the CTR means your BSA team will send it back, and you'll have to track down the customer again.

Now you'll need to collect the personal information that goes on the Currency Transaction Report. This is the part that takes the most time, so let the customer know it'll be a few extra minutes. You're gathering: - **Full legal name** -- as it appears on their ID, not nicknames - **Date of birth and current address** -- verify these match what's in your system if they're an existing customer - **SSN or TIN** -- if the customer refuses, note that in the form but don't stop the transaction. You're still required to file the CTR even without it - **Occupation and employer** -- a quick question, but it's required on the form - **Source of funds** (for deposits) or **intended use** (for withdrawals) -- ask this casually. Most people won't think twice about it **Watch out for**: Customers who get nervous or evasive when you ask about the source of funds. That doesn't necessarily mean anything is wrong, but if your gut says something's off, make a note and flag it for your BSA officer after the transaction. Don't confront the customer -- just document what you observed. **Common sources you'll hear**: Business revenue, property sale, insurance payout, inheritance. If they say something vague like "savings," it's fine to ask a follow-up like "Was this from a home sale or something similar?"

You're in the home stretch. Process the cash transaction through your teller system as you normally would, then complete the CTR filing. Key things to remember: - **File the CTR within 15 calendar days** of the transaction (31 CFR 1010.306). Most banks want it done same-day or next business day, so don't put it off - **You can't tell the customer a CTR is being filed** -- this is called "tipping off" and it's prohibited. If they ask why you're collecting extra information, just say it's standard procedure for transactions of this size - **Double-check every field** before submitting -- FinCEN rejections for typos or missing data create extra work for everyone - **Record the CTR reference number** once it's filed. You'll need it if there are questions later **If the transaction gets declined** (system hold, account issue, etc.), you still need to file the CTR if the customer attempted the transaction. A declined transaction doesn't remove the reporting requirement. **After you're done**: Make sure the CTR reference number is linked to the transaction in your system. If your branch uses a log book for large cash transactions, enter it there too. Your BSA officer will review these during their regular audits.