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If an individual customer withdraws money from a joint account, do both account holders need to be listed on the Currency Transaction Report?

My bank had a customer who withdrew $10,500 cash from a joint account (co-owned with his wife) to purchase equipment for his sole-ownership business. His wife was not present at the time of withdrawal. The teller entered the customer’s information as customer and transactor on the currency transaction report (CTR). However, the bank’s Bank Secrecy Act Officer is saying that the teller was also required to enter the wife’s information on the CTR. My interpretation of the CTR requirements is that the bank is not required to enter the wife’s name and information on the CTR unless the bank specifically knows that the wife would benefit from the money withdrawn, which we do not believe is true. Who is correct?

You are correct. In this situation, the bank is not required to enter the wife’s information and identification on the CTR. FinCEN resolved this issue in the CTR FAQs, Question #24. This Q&A makes clear that the bank is only required to include a joint account owner’s information in the CTR if when it has knowledge that the transaction was conducted on that owner’s behalf. If the bank does not have such knowledge (or is unsure), it is not required to include the joint account owner’s information although it is not prohibited from including it, either. (February 2020)

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