We have a customer who is refusing to enter a remitter for a cashier’s check. We believe that the customer should enter in a remitter, for BSA purposes. The customer is very upset and wants to leave the remitter line blank. Is there any regulation we can point to?

We are not aware of any law or regulation that requires a bank to identify a remitter on a cashier’s check. However, both the Illinois Currency Reporting Act and FinCEN regulations require banks to obtain and record certain information for cashier’s checks issued for $3,000 or more, including the identity of the purchaser. In keeping with the spirit of these requirements, we believe your bank has the discretion to maintain a policy requiring a remitter to be listed on a cashier’s check.

For resources related to our guidance, please see:

  • Uniform Commercial Code, 810 ILCS 5/3-103 (11) (“‘Remitter’ means a person that purchases an instrument from its issuer if the instrument is payable to an identified person other than the purchaser.”)
  • FinCEN Regulations, 31 CFR 1010.415 (Requires financial institutions to maintain records for cashier’s checks for $3,000 or more, including the name and other identifying information of the purchaser)
  • Illinois Currency Reporting Act, 205 ILCS 685/5 (Requires financial institutions to verify the identity of the purchaser of a cashier’s check for $3,000 or more)