Okay, this is the first time I've come across this and looking for an answer.

Customer owns multiple convenience stores, he normally makes the deposit. However, on one day he makes a transaction that exceeds the CTR threshholds. On that same day, an employee makes a deposit to a different branch that also exceeds the CTR threshholds.

I know that Section A will have the Customer's name and DBA listed. I know that I have to list the employee on Section B. I know that this is a multiple transaction and person CTR.

So the question is, since the customer is listed in Section A, have I satisfied the requirements or do I also need to list him this as an additional person? I am leaning towards the second option since on Section B is says "Section B-Individual(s) Conducting Transaction(s) (if other than above).

My reasoning for this is that if this CTR was being reviewed it could easily be construed that Customer and DBA is being reported on and that the employee listed in Section B is the only one who conducted all the transactions.

Thanks in advance for any advice.

Seadevil

You always have to indicate who conducted a transaction (when you know). For persons (like your sole proprietor) who conduct them themselves, you check "conducted on own behalf" just above Section B.

In the scenario you've described, you check the "multiple persons" box in item #1 at the top of the form to indicate you are reporting either multiple beneficiaries or multiple transactors. Then you complete the rest of the CTR front as if the employee was not a participant. Flip the CTR over and complete a Section B entry for the employee.

Thanks John.