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#1570162 - 06/27/11 01:48 PM Do I file a separate CTR?
AquaMarine Offline
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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?

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#1570167 - 06/27/11 01:52 PM Re: Do I file a separate CTR? AquaMarine
AFaquir Offline
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IMO- You have 2 separate CTR transactions.
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#1570436 - 06/27/11 05:58 PM Re: Do I file a separate CTR? AFaquir
nemsi Offline
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Joined: Nov 2005
Posts: 383
I agree- 2 separate CTRs.

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#1570440 - 06/27/11 05:51 PM Re: Do I file a separate CTR? nemsi
rlcarey Online
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Joined: Jul 2001
Posts: 79,959
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.
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