Regulatory Compliance: Bank Responsibility for Cash Deposits from Overseas Relatives

Bank Responsibility for Cash Deposits from Overseas Relatives

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Question

Mrs. Evans, a customer of First National Bank, deposits $15,000 in cash to her account. During the transaction, Mrs. Evans explains that she received the money in the mail from her sister in Europe. What responsibility does the bank have?

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Explanations

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A. B. C. D.

D

The bank's responsibility in this situation is to comply with the regulatory requirements of the Bank Secrecy Act (BSA), which is designed to prevent money laundering and other illegal activities. One of the key requirements of the BSA is for financial institutions to report certain types of transactions to the government, including large cash transactions.

In this case, Mrs. Evans has deposited $15,000 in cash to her account. This amount exceeds the $10,000 threshold for cash transactions that triggers reporting requirements under the BSA. As a result, the bank is required to complete a Currency Transaction Report (CTR) and file it with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.

The CTR includes information such as the identity of the customer, the amount and type of transaction, and the source of the funds. In this case, Mrs. Evans has explained that she received the money in the mail from her sister in Europe. This information should be included in the CTR.

The bank is not required to complete a United States Customs form 4790 (CMIR) in this situation. A CMIR is used to report the physical transportation of currency or monetary instruments into or out of the United States, and it is typically used by individuals or businesses that are transporting large amounts of cash across borders. Mrs. Evans has not physically transported the cash into the United States, so a CMIR is not necessary.

Therefore, the correct answer is A: Complete a Currency Transaction Report (CTR). Option D is incorrect because the bank cannot encourage Mrs. Evans to file a CMIR since it is not necessary in this situation.