Skip to content
BOL Conferences
Thread Options
#1817416 - 05/24/13 04:41 PM CTR w multiple and aggregated trans
Local banker Offline
100 Club
Joined: Feb 2008
Posts: 129
I've got to complete a CTR for a corporation with multiple DBAs/locations for transactions that took place on Monday's business day (transactions were conducted on Sat & Mon). There was a single transaction for a cash out over $10000.00 so I know the transactor on that one, but there was also multiple cash ins all under $10,000 individually but when aggregated total over $10,000. Based on the date and time of transactions, I can tell that the transactor of the single out did 2 of the aggregated transactions. I will include those on his page of the CTR, but I do not know who did the other deposits. Can I just complete the pages on behalf of the corporation without having the person conducting transaction for another? It should all total on Part II and I will check aggregated transactions. I just want to make sure I'm not missing something.

Return to Top
BSA/AML/CIP/OFAC Forum
#1817633 - 05/25/13 07:41 AM Re: CTR w multiple and aggregated trans Local banker
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
You cannot check "aggregate transactions" as you have a transaction to report that is over $10,000. You report the amount associated with the person you can identify as a conductor and check the multiple transactions box which explain the difference between the amount reported on the one conductor and the total of all the transactions. Aggregate transactions can only be used when none of the individual transaction were over $10,000 and at least one of the transactions was conducted through a teller.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1818195 - 05/29/13 04:26 PM Re: CTR w multiple and aggregated trans Local banker
Freemanp Offline
New Poster
Freemanp
Joined: May 2013
Posts: 2
Watertown, SD
I have business A that has 5 owners and business B that has 4. Two of the owers of A are also owenrs of B. The business' are located in two different cities using two different branches. If A deposits $6,000 and B deposits $6,000 on the same day, how do I fill out the CTR if I need to fill one out at all? Both deposits were done in the night drop so the indevidual conducting is unkown. Would I fill it out using A and B as "Person conducitng transaction for another" and the two owners as "Person on whose behalf transaction was conducted"? Please advise.

Return to Top
#1818203 - 05/29/13 04:38 PM Re: CTR w multiple and aggregated trans Local banker
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
Unless you have reason to believe that the businesses are operating as a single entity, no CTR is required. Common ownership does not automatically trigger aggegation.

See FIN-2012-G001
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top

Moderator:  Andy_Z