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#1565785 - 06/16/11 03:35 PM CTR?
NancyF Offline
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NancyF
Joined: Dec 2001
Posts: 173
PA
Unincorporated business makes cash deposit of approximately $3,400 into two business checking accounts. Husband (business owner) and wife deposit $5,000 cash into joint savings account. Adult son, who works at business, deposits almost $4,000 cash into his individual checking account. Do I need to aggregate all the transactions and file a CTR?

We file CTRs on the business accounts for cash deposits about 6 to 10 times a year. Normal daily cash deposits for the business, a gas station, are between $3 - 4,000.

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#1565811 - 06/16/11 03:58 PM Re: CTR? NancyF
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
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I would say that you do not have a CTR issue... You have a wait and see SAR issue.

Track the movement of this money... if it or similar amounts end up transferred into the business accounts electronically you certainly have a SAR structuring issue. If they don't then maybe they just took their half year dividends straight from the register and store safe.

Cheers!
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#1565829 - 06/16/11 04:15 PM Re: CTR? AFaquir
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
If by "unincorporated business" you mean sole proprietor, you will need to aggregate all deposits of buiness and owner (and of course, the conductor comes into play if he is walking through the door with multiple cash deposits).

My question is along the lines of the above. What is the source of the cash being deposited into personal accounts?
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#1567957 - 06/21/11 11:40 PM Re: CTR? BrendaC
JackieN Offline
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Joined: Mar 2004
Posts: 44
You definetely need to have an understanding of the source of the funds deposited into the personal accounts. However, a CTR is not required based on the example you provided. No individual brought over $10,000 cash into the bank and no beneficiary received over $10,000 in cash.

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