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#397277 - 08/04/05 09:31 PM CTR?
Anonymous
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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.

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#397278 - 08/04/05 09:35 PM Re: CTR?
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If a single individual presented the deposits to the bank - you have to aggregate.

If all deposits were made by separate individuals, and you believe that the business are truely separate - you would not have to aggregate.
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#397279 - 08/04/05 10:11 PM Re: CTR?
Anonymous
Unregistered

Thank you. I love it when we do things right.

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