Thread Options
#1979106 - 11/25/14 08:28 PM Aggregate for CTR Purposes?
BSA Aficionado Offline
Joined: Feb 2013
Posts: 98
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?

Return to Top
#1979111 - 11/25/14 08:35 PM Re: Aggregate for CTR Purposes? BSA Aficionado
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1979235 - 11/26/14 10:19 AM Re: Aggregate for CTR Purposes? BSA Aficionado
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z