Question:

If a Currency Transaction Report (CTR) reportable cash transaction happens on a joint account, does the CTR need to include the names of all joint owners, or only the member who conducted the transaction?

I suspect we need to include all joint owners and check Box 2c “Person on whose behalf transaction was conducted” for those who potentially benefit from the transaction but did not conduct the transaction.

Related question – if both joint owners are present when a CTR reportable withdrawal is conducted, would we check box 2a for both individuals?

Answer:

You are correct. If you have a CTR reportable deposit transaction, you will list the person who conducted the transaction, plus everyone who benefited from the transaction – all joint account holders.

For a CTR reportable withdrawal, you will list the person who conducted the transaction, plus everyone who benefited from the transaction. In this case, you will only list joint account holders if you have knowledge the transaction was done for their benefit. Interestingly, if you don’t know who else will benefit from the withdrawal, FinCEN says you can leave joint account holders off the CTR or included them. Up to you. See questions 23 and 24 on FinCEN’s CTR FAQs: https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr