Joe has 2 personal accounts; on 1 he is the sole owner and on the other there is a joint account-holder named Mary. Joe conducts 2 cash withdrawals; $7,000 from his solely-owned account and $3,500 from his joint account. We always show all owners on cash in or cash out CTRs but in this case I don't think we should show Mary since she only could have benefitted from $3,500. Any other opinions on this? Thanks.

If it were cash in to the joint account, you would add Mary because she benefitted from the transaction. Since these were both cash withdrawals, you only report the conductor.

24. How do I properly complete Part I on the FinCEN CTR for withdrawals from a joint account? What amounts do we show in Item 22 for each Part I? For example, John and Jane Smith have a joint account together. During one business day, John Smith withdrew $12,000 from the account.

Since John Smith made a withdrawal from the joint account in excess of $10,000, then the financial institution would list Jane Smith’s information only if it has knowledge that the transaction was also being conducted on her behalf. If the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, then it would neither be required to nor prohibited from listing Jane Smith in a second Part I.

Therefore, if the financial institution does not have knowledge that the withdrawal was conducted on behalf of Jane Smith, the financial institution would complete a Part I on John Smith. For Item 2 of Part I, the financial institution would check 2a “Person conducting transaction on own behalf” and complete the applicable information for John Smith. Item 22 for Part I on John Smith would be completed by entering $12,000 and providing the account number affected.

However, if the financial institution does have knowledge the withdrawal was completed on behalf of both John Smith and Jane Smith, the financial institution must complete two Part Is. In completing a Part I on John Smith, the financial institution would check 2a “Person conducting transaction on own behalf” and complete the applicable information for John Smith. In completing a Part I on Jane Smith, the financial institution would check 2c “Person on whose behalf transaction was conducted” and complete the applicable information for Jane Smith. Item 22 for each Part I would be completed similarly by entering $12,000 and providing the account number affected.

I have a joint account with husband and wife. Wife deposits $10,000.00 cash earlier in the day. Conversation with the customer, she has been saving to buy a house and is in the process of doing so. Later the same day, husband deposits $20,000.00 in cash. Deposits were made into the same account. Question: Do I file CTR on just the husband for $20,000.00 or do I combine the total cash in and file on both?

Since it is a joint account and they both benefitted you would file the CTR for both deposits.

Aggregation rules require that you would have two Part 1's, one for each account holder. Since both brought in one deposit, check box 2a "Conducted on own behalf", box 3 since each benefitted from more than one transaction, and report $30,000 for each on line 20.

Originally Posted By rlcarey

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However, if the financial institution does have knowledge the withdrawal was completed on behalf of both John Smith and Jane Smith, the financial institution must complete two Part Is. In completing a Part I on John Smith, the financial institution would check 2a �Person conducting transaction on own behalf� and complete the applicable information for John Smith. In completing a Part I on Jane Smith, the financial institution would check 2c �Person on whose behalf transaction was conducted� and complete the applicable information for Jane Smith. Item 22 for each Part I would be completed similarly by entering $12,000 and providing the account number affected.



Extension to the original question: What if BOTH account holders were present at the time of transaction? Would you check "conducted on own behalf" for both? or one as "Conducted on own behalf" and one "Person on whose behalf transaction was conducted"?

I would mark both as conducted on own behalf.

Thank you, Dani! Perhaps I am overthinking it, but I see the teller physically handing the cash to ONE person making them the true conductor on behalf of themselves and on behalf of someone else. Party B - did not truly conduct the transaction so how could it be that he "conducted on his own behalf?"

Okay, after rereading the FinCen CTR FAQ's for the umpteenth time....# 16 specifically....I see that what you (Dani) suggested appears to be correct...despite my "over" thinking it.

Thank you again for response. Appreciate it.

HELP!
If you have two people that a check is made out to, and both endorse the check, how is a CTR filled out?
One CTR, or 2 separate ones?

It's 1 transaction, so 1 CTR. You just list all parties that either benefitted from the transaction and/or conducted the transaction.

Thank you!