Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
Question: We are having some difficulty understanding how to treat multiple transactions conducted by an individual for more than one account or on behalf of more than one individual or company. For example, if an armored car service brings in deposits for two companies and each deposit is $7,000.00, must we file a CTR because the deposits were made by the same individual?
Answer: This type of multiple deposit can create some murky situations. Let's break down your example into several situations. If the two businesses in your example are truly unrelated, you do not have to aggregate the deposits. Since both deposits are under $10,000, you do not have to file a CTR.
Now let's assume that the two companies are related. This would be the case if two companies with common ownership use the same armored car service. Now the money is coming in from a common source, the ownership of the two companies. Therefore, even though it is going into two different company's accounts, you should aggregate the deposits and file a CTR.
Finally, if there is anything suspicious about the transaction, it may be appropriate to file a Suspicious Activity Report. You should determine whether to file a SAR based on the nature of the activity and the amount involved. In other words, the determination to file a SAR should be made based on those rules and not on the determination that the transaction is or is not subject to the CTR filing requirements-unless of course you have reason to believe that the depositors are structuring the deposits to avoid having a CTR filed.
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 12, 7/96
Rate This Article
Current Rating For the Feature:
Content-type:text/html
File or Directory cannot be opened.
Default error message. |
|