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#375908 - 06/22/05 05:34 AM CTR help requested - multiple accounts
Anonymous
Unregistered

We have four business accounts with separate EINs and operate under different names. However, we are aware that they are owned by the same corporation.

When completing a CTR, do we complete a separate CTR for each business or do we consolidate under one with multiple Part I Section A's or does it really matter?

Each business conducts their own transactions and at different times and generally the transaction alone would require a CTR by itself without aggregating. There are days when only one would have activity or maybe three business accounts would have activity on the same business day.

e.g. Business A - $12,000
Business B - $15,000
Business C - $8,500

Keeping in mind that the transactions are generally conducted by different individuals/armor carriers at different times for the different businesses.

One CTR for Business A and
One CTR for Business B
OR
One CTR for Businesses A, B, and C for $35,500?

Thanks.

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#375909 - 06/22/05 12:46 PM Re: CTR help requested - multiple accounts
LauraL Offline
Gold Star
Joined: Jun 2005
Posts: 365
Georgia
This is just my opinion from BSA research, but I would do separate CTRs for each business. They each have their own EIN, so I would not aggregate them together, even though they may be owned by the same corporation.
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#375910 - 06/22/05 03:02 PM Re: CTR help requested - multiple accounts
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
I agree with Laura because each business is a separate entity. I would also monitor these customers closely for suspicious activity.
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