A customer owns several businesses, all of which are seperate entities, no DBAs, different TINs. On Monday he brought in deposits for three of his businesses. None of the deposits had over $10,000 in cash, but combined, (for the benefit of the owner?), it was over. Should we:
1) Aggregate the deposits, do a CTR, check multiple transactions and multiple persons, put the business names in section A(s), the owner's name in section B(s), and list all three accounts that were effected?
2) Not aggregate the transactions and not do a CTR as we are talking about three seperate business entities?
We chose option 1.
Thanks for the help.