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#359874 - 05/16/05 07:10 PM CTR Question
runawayctr Offline
New Poster
Joined: May 2005
Posts: 2
Tennessee
HELP!! If a corporation has 2 accounts under same EIN# plus another account under different EIN# and Deposits are made at different locations, do you mark multiple transactions and not fill in Section B or fill in Section B for all people bringing in deposits? My Holding company and I are disagreeing. The FDIC in November, (during BSA audit) told me I was covered if I mark Multilple, and the BSA officer at the Holding company says I have to list all of the depositors.

Will you please give me your input!!!!!!!
Sincerely,
runawayctr
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MissMissy

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#359875 - 05/16/05 07:13 PM Re: CTR Question
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Why does the other account have a different EIN? Is it is wholly owned subsidiary, could it be a different company altogether, or even some type of data entry error? You don't have to be in this business very long to see all of these and more!
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#359876 - 05/16/05 08:06 PM Re: CTR Question
Anonymous
Unregistered

Different Corporations, different EIN# with exact same signers/owners of the account.

One company sells tractors and the other company sells power sport equipment.
Thanks for your input!
MissMissy

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#359877 - 05/16/05 08:37 PM Re: CTR Question
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
If the same person (we'll call him the runner) deposits cash to both companies, I would file a multple person CTR. I would list each corporation separately in Section A as persons on whose behalf the transactions were conducted. If the runner deposited $10 cash into his personal account, he would go in Section A as well.

Since these are two separate entities, I would not aggregate these deposits into one CTR unless I had knowledge that a common person was involved in the deposit activity (or unless the deposits came in the same night deposit bag). I would take appropriate investigative measures to insure both companies were operating as legitimate businesses (not a front business) to insure a suspicous activity situation did not exist.
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