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The Chief National Bank Examiner's Office will be responsible for
direct coordination of efforts with Treasury. This includes
disseminating information received from Treasury, such as notices
of investigations and analysis reports of CTR filings, to District
management and other affected parties. Under the oversight and
direction of the Chief National Bank Examiner's Office, District
management shall establish procedures for: 1) communicating in
writing to examiners-in-charge information regarding institutions
designated for suspected non-compliance including any special
guidance on procedures to follow; 2) monitoring that findings are
adequately reported and that appropriate followup is made; and
3) monitoring that examinations include Bank Secrecy Act compliance
procedures as outlined in this issuance. The District offices in
turn will report quarterly on their findings and status of
examinations to the Chief National Bank Examiner's Office as
required by PPM 5000-13, dated November 1, 1982. In addition,
when banks have come forward and discussed violations with the
Department of Treasury and District offices, memoranda of such
meetings should be prepared and forwarded to the Chief National
Bank Examiner's Office.

Referrals for Potential Violation of Law

Examining and District personnel are reminded to review a bank's procedures and transactions to determine if there are violations of the Bank Secrecy Act that should be the subject of a referral for possible criminal and/or civil money penalties. A separate memorandum detailing the facts of the violation may be necessary for ultimate referral. Also, unless it is believed that there is a possibility of destruction of evidence or a cover-up, examiners may discuss the problems with appropriate bank officers to obtain corrective action. As in cases of other violations of law, they should be cited in the Report of Examination. Examiners should not, however, indicate that by correcting the violations no .further action will be taken by the Treasury Department. District offices should review and forward all referrals of violations with recommendations to the CNBE for review and coordination with the Treasury Department.

Date:

April 24, 1985

Page 4 of 5

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Comptroller's Handbook For National Bank Examiners. Section 201.1, page 2, "Currency Transaction", 6th and 5th lines from bottom, delete: If violations are disclosed," Section 201.3, page 2, question 9.f., last sentence, delete: In the absence of any no answers". Insert after the word "retain": "a copy of". Place a note in the margin at both locations: See EC 228.

ORIGINATING OFFICE

Chief National Bank Examiner, Commercial Examinations Division, (202) 447-1164.

H. Joe Seby

Senior Deputy Comptroller

for Bank Supervision

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TO: Chief Executive Officers of All National Banks, Officers in
Charge of Federal Branches and Agencies, Deputy Comptrollers
(Districts), District Administrators, Department and Division
heads and All Examining Personnel

Attached for your information is an Internal kevenue Service press
release issued December 19, 1985 regarding IRS Form 4789, Currency
Transaction Report. You will note that the implementation date is
July 1, 1986. For the period January 1 through June 30, 1986
continue filing the existing Form 4769.

This Banking Bulletin automatically expires July 1, 1986.

John F. Imney.

John F. Downey

Chief National Bank Examiner

Attachment

Date: December 20, 1985

Page 1 of 1

News
Release

For Release: 12/19/85

Department of the Treasury
Internal Revenue Service
Public Affairs Division
Washington, DC 20224

Media Contact: Tel. (202) 666-4024
Copies:

IR-85-119

Tel. (202) 566-4054

Washington-The Internal Revenue Service today announced that a revised Form 4789, Currency Transaction Report, will became effective on July 1, 1986, for transactions of more than $10,000.

Until that date, the IRS said financial institutions should continue to file the existing Form 4789. Additional supplies of the existing form can be ordered from IRS forms distribution centers.

Financial institutions can obtain a copy of the newly revised Form 4789 for the purpose of developing internal procedures or making necessary computer programming changes by sending a request to the IRS Data Center, Attn: Currency and Banking Report División, 1300 John C. Lodge Freeway, Detroit, MI 48226.

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TO:

Chief Executive Officers of All National Banks, Officers
in Charge of Federal Branches and Agencies. Deputy
Comptroller (Districts). District Administrators,

Department and Division Heads and All Examining Personnel

PURPOSE

This issuance provides guidelines for amending/refiling
Currency Transaction Reports (CTR). Form 4789.

BACKGROUND

The Internal Revenue Service (IRS) receives CTRS and enters
this information into a data base. Due to the increased volume
of CTRS being filed, processing backlogs have occurred. The
cause of the increase is: 1) greater compliance awareness by
the entities required to file CTRS and 2) an influx of CTRS
being amended because of prior inadequacies.

PROCEDURES

Amended CTRS have resulted in duplicate entries into the data
base. To minimize this occurrence the Department of the
Treasury and IRS have developed guidelines for amending a CTR.
The guidelines should be implemented immediately.

1. On a copy of the CTR originally filed, circle in red the
incorrect, illegible or missing information.

2.

3.

On a blank CTR, enter "AMENDED" or "CORRECTED" in the top
margin above the Currency Transaction Report legend.

Enter only the correct or amended information on the blank
form in the appropriate line item or box.

4.

Sign and date the amended or corrected form.

5.

Staple the amended or corrected form on top of the copy of
the originally filed form.

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