Jump to Content
ABA: The American Bankers Association
Skip Section Navigation

Should the balance from an abandoned lockbox that was transferred to an internal general ledger account be recoreded in a currency transaction report?

My bank drilled a safe-deposit box that was considered abandoned and found over $10,000 in cash in the box. The box owner cannot be located, and there is no deposit account in this customer’s name on record. The bank deposited the cash to an internal general ledger account. Presumably, the amount will ultimately be turned over to the state in accordance with applicable abandoned property law. Should the bank complete a currency transaction report and, if so, how should it complete the form since there is no account and no transactor?

FinCEN’s Resource Center acknowledges that FinCEN has no guidance that specifically address this scenario. However, a bank should still file a currency transaction report, as banks must file a currency transaction report for each transaction in currency “by, through, or to the bank.”

The bank may complete the currency transaction report with the customer's information (based on what the bank has on file) as the "person on whose behalf transaction was conducted," since the box belonged to that person, and may list the general ledger account number if that is the account to which the funds were deposited. (November 2018)

Compliance Hotline

Have a compliance-related question? We're here to help. Members, reach us by phone or email.