Question:

Hi Heather,

Hoping I could ask your advice on a fraud issue we had yesterday.  Someone impersonating our member withdrew cash at two of our offices that totaled more than $10,000.  My question is how should I complete CTR since we know it wasn’t our member?  Can I say “unknown” for everything?

Answer:

Wowza. I have no clue whatsoever. Since a CTR with no conductor is huge bit of exam bait, I don’t want you to do that unless you have (preferably written) instructions from FinCEN. You can contact the FinCEN help desk here: https://www.fincen.gov/contact

Please let me know what they say.

FinCEN’s Answer:

Heather, here is the response I received from FinCEN:

If you do not know the person that actually conducted the transaction, you may select “Unknown” for all critical identifying fields on Part I.

Thank you for your advice to check with them.  I will definitely save their response with the CTR.