If you believe the transactions were completed by the same individual, and you have knowledge of the transactions, you must combine them into a single CTR. Check the ATM box to indicate that one of the transactions was at an ATM. Check box 3 to indicate you're reporting multiple transactions. In the Part I record for the individual, check box 2a and combine the dollar amounts and list both account numbers in item 22. If the $34,000 withdrawal was on behalf of the business, create a Part I record with box 2c checked, and include the business account number in item 22.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8