CTRs for Multiple Accounts with Same Ownership

Question:

Hello, Heather!

I was hoping you could help me with a question regarding a CTR filing. We had a member come in and withdraw cash from his business account that he owns. Then in a separate transaction he withdrew cash from his personal account. The purpose of both transactions are the same, and the aggregate total was over 10k.

Do we need to look at a transactor doing multiple transactions that hit the threshold, or because the business is its own entity and has a separate EIN, would that transaction not be counted toward the total amount?

Answer:

The trigger for CTRs is a cash transaction made by or on behalf of the same person. A CTR is triggered in this instance because the same person conducted both transactions and the total cash withdrawal was over $10,000.00

How you fill out Part 1 of the CTR form (and how many Part 1s you fill out) will depend on if the business is a sole proprietorship or a legal entity (LLC, corporation, etc.).

Bank Secrecy Act, Compliance, Currency Transaction Report

CTRs for Multiple Accounts with Same Ownership

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