Skip to content
BOL Conferences
Thread Options
#1570162 - 06/27/11 01:48 PM Do I file a separate CTR?
AquaMarine Offline
100 Club
Joined: Jun 2011
Posts: 156
New York, NY
We have a customer who is the owner and has two business accounts (with different EINs) with us. The owner makes the deposits into business account A and the manager into business account B, both exceeding the threshold.

My question is, although the two business accounts share common ownership, do these transactions warrant one or two separate CTRs?

Thanks!
_________________________
"Give thanks in all circumstances; for this is God's will for you in Christ Jesus." -Thessalonians 5:18


Return to Top
BSA/AML/CIP/OFAC Forum
#1570167 - 06/27/11 01:52 PM Re: Do I file a separate CTR? AquaMarine
AFaquir Offline
Platinum Poster
AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
IMO- You have 2 separate CTR transactions.
_________________________
In life, there is a lot less that could get better and a lot more that could get worse.

MBA Fin/MBS HR

My views only!

Return to Top
#1570436 - 06/27/11 05:58 PM Re: Do I file a separate CTR? AFaquir
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
I agree- 2 separate CTRs.

Return to Top
#1570440 - 06/27/11 05:51 PM Re: Do I file a separate CTR? nemsi
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
I agree, as long as it is apparent that the businesses are run independently and funds are not routinely comingled. There is a FinCEN opinion on this, but I don't have the citation handy.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z