The thinking behind FinCEN's guidance may be based on the fact that it's not necessary that the "person on whose behalf the transaction is conducted" actually benefit from the transaction. A trustee has a duty to deposit funds belonging to the trust, and completing the deposit discharges that responsibility; thus, the deposit can be said to be made on behalf of the trustee, as well as on behalf of the trust itself.
If the trustee is the conductor of the transaction, the Trust is included in the CTR using box 2c and the trustee is included using box 2a, because 2a trumps 2b when both apply to the role of the conductor.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8