Financial institutions often receive large cash deposits via the night drop, especially from their business customers. We had an institution reach out to us recently, after receiving a deposit in the night drop that exceed $10,000 in cash. They knew they would obviously need to complete a Currency Transaction Report (CTR) but were confused on how to fill it out since they didn’t know the identity of the person leaving the deposit in the night drop.
The important thing is you don’t want to assume the depositor’s identity, even if there is some kind of note or other indication of who it might possibly be (e.g., “Dropped off by John Doe”). If the institution cannot verify the identity of the person making the deposit, the transactor is unknown.
In this instance, the CTR should be completed as follows:
- Part I – Person Involved in Transaction(s)
Complete this section for the business entity to whose account the deposit was made. Select Item 2c “Person on whose behalf the transaction was conducted”.
- Part II – Amount and Type of Transaction(s)
Indicate that the transaction was a night drop by selecting “Night Deposit” in Item 24.
While this scenario is not specifically addressed in FinCEN’s “Frequently Asked Questions Regarding the FinCEN Currency Transaction Report (CTR)”, we did find an old FinCEN training where they addressed a very similar scenario (although in this case there were multiple night deposits). It stated:
A bank receives two night deposits (each transaction below the reporting threshold) that totaled over $10,000 that are to be deposited into one business account.
The financial institution would file a CTR by completing a Part I on the entity to which the account, where the funds being deposited belongs by selecting Item 2c (person on whose behalf transaction was conducted) and Item 3 (Multiple Transactions). Additionally, the financial institution would select “Night Deposit” in Item 24 as no identifying information on the transactor was collected.
Published
2025/07/25
