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#1979106 - 11/25/14 08:28 PM Aggregate for CTR Purposes?
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We have a customer who owns multiple entities. One entity is a Petroleum Merchant Wholesaler and the other entities are Gasoline Stations with Convenience Stores. When reviewing CTR activity, we observed on-us checks being written from the gas station accounts to the wholesaler account with a notation of "loads" which we are interpeting as a gasoline delivery. Does this type of activity warrant us aggregating the transactions for the involved busineses pursuant to FIN-2012_G001?

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#1979111 - 11/25/14 08:35 PM Re: Aggregate for CTR Purposes? BSA Aficionado
John Burnett Offline
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John Burnett
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It's not unusual to see vertical integration in this business. I don't know that I'd consider what you've described as conclusive evidence the businesses aren't being independently operated. But I would look further to see if there are other indicia the businesses need to be treated as a single enterprise for CTR aggregation.
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#1979235 - 11/26/14 10:19 AM Re: Aggregate for CTR Purposes? BSA Aficionado
Elwood P. Dowd Offline
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Elwood P. Dowd
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FWIW, I agree with John. The gasoline stations need to purchase fuel. The fact that they are purchasing it from a related entity does not mean the entities are not being operated separately.

Activity that you would not expect, gasoline stations and convenience stores that are separate entities making payments to each other, would suggest that the various entities are not being operated separately.

My assumption is that the wholesaler is not part of your aggregation question; i.e. they are not depositing cash.
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