We had a non-customer cash an on-us payroll check for cash from our customer's account. The customer also came in the same day and withdrew cash from the same business account which resulted in total cash out that exceed the $10,000. My question is do I have to also list the non-customer party that cashed his check from the commerical account on the CTR or do I just list multiple transactions?
If I understand you correctly the payroll amount went to the customer's employee and the rest went to the business customer itself. Are you thinking that you need to aggregate the two? I don't believe you would have to, since the transactions were conducted by and benefitted different parties.
You are correct in that they benefitted different parties. We just assumed they had to be aggregated since it affected the same commerical account
If that was the case you would have to file on every payroll customer every payday at a lot of banks. The key is same beneficiary or same conductor = >$10,000.
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