I have a customer that deposited $8,500.00 into a business account that he and his wife are signers on. The account is under a TIN. We know the business is no longer in operation but they continue to use it as a personal acct. The wife is joint owner on an account with daughter. Wife deposits $8,760.00 on the same day. In conversation with wife hen ask for ID she commented that she didn't need ID because she did not deposit more than $10,000.00 into the account and that's the reason her husband deposited the money into his account instead of putting it all in one account. They purchased a vehicle over the weekend and would have paid cash but didn't want the government in their business.
Long story short, I have a few questions on how to report this accurately.
(1)Do I file a CTR as well as a SAR? And if so, do I include the daughter on the CTR since she is a joint account holder on one of the accounts?
(2)Do I complete part 1 on husband for $8,500.00 conducted on own behalf, part 1 on wife for $8,500.00 whose behalf transaction conducted, another part 1 on wife for $8,760.00 conducted on own behave, part 1 on daughter for $8,760.00(joint acct.owner) whose behalf transaction conducted.

Any comments are greatly appreciated!!!

Yes to all of the above along with closing these accounts pronto.

Thanks

You would have a part one on the husband ($8,500), 1 part 1 on the wife for both transactons (total $17,260) and a part one for the daughter ($8,760). Not 2 separate part 1 for the wife as you described above. You would check conducted on own behalf for the wife as that box trumps the others.

That's true. I read right by that. A person only appears once on a CTR.

How about the fact that the cash was deposited into an account for a business with it's own TIN? Despite the fact that Help!! indicates the bank has knowledge the business does not actually exist any longer and the former business signers are using it as a personal account, doesn't the Business's info need to be reflected on the CTR with a Part I also? Maybe I'm just confused.