The two banks settle through an internal account procedure without any physicaltransfer of cash between the banks. Bank A credits the customer’s account in the amount of the cashdeposit.
Pursuant to an agency agreementbetween the banks, Bank B processes the cash deposit and sends the appropriate transactioninformation to Bank A. The customer makes a cash deposit of$12,000 at Bank B for credit to his account at Bank A. A customermaintains an account at Bank A, but not at Bank B. In that letter, you requested a ruling on theapplication of the rules relating to the filing of a currency transaction report (“CTR”), asauthorized under the Bank Secrecy Act and its implementing regulations, to the facts outlinedbelow.īank A and Bank B are subsidiaries of the same bank holding company. This responds to your letter dated February 25, 2000, on behalf (the “Bank”), to theFinancial Crimes Enforcement Network (“FinCEN”).
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