The "fishing boat" ruling is repeatedly acknowledged in the prior threads linked by Wonder Woman above. It is also referenced
post 2101320 in a current thread that plows the same field.
In my opinion, the most nonsensical rulings FinCEN ever issued are:
* Armored car I,
* Sole proprietorship I, and
* the fishing boat.
As suggested by the "I," FinCEN ultimately corrected the first two.
As noted repeatedly in all of the threads linked above, the practice of cashing multiple payroll checks for a single person facilitates:
* human trafficking,
* padded payrolls, and
* employment of undocumented workers.
Any interpretation that the CTR does not need to include the information on all payees when the conductor is clearly acting as an agent on their behalf reflects an amount of naiveté that cannot be rivaled outside the Beltway.