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#1997254 - 02/20/15 03:53 PM CTR Aggregation
BSA/AML Offline
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Joined: Mar 2013
Posts: 39
We have a customer who owns a convenience store that also sells lottery tickets and is cash intensive. We usually do about 1-2 CTRs on this customer a week. He is the sole owner of the business and the only signer on the business checking account. He also has a personal checking account in which he is the sole signer on. When he brings in the cash for his business he also makes a small cash deposit into his checking account. When filing CTRs for on the customer I have been putting both he and the business as the entities on whose behalf the CTR is being filed and checking off the Multiple transactions and conducted on own behalf boxes. To review these cash transactions I check a large cash transaction report (Anything over $5,000.00)that pulls information based on account number and a daily cash report that pulls information based on the TIN number. Is this correct or should I be filing based on the customer since he is the sole owner of the business?

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#1997294 - 02/20/15 05:06 PM Re: CTR Aggregation BSA/AML
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
"The business." Corporation, LLC, sole proprietorship?

If it's an entity, the owner does not benefit from a deposit to the entity's account. FIN 2012-G001
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#1997359 - 02/20/15 06:48 PM Re: CTR Aggregation BSA/AML
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Joined: Mar 2013
Posts: 39
It is an Incorporated Business.

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#1997451 - 02/21/15 02:13 PM Re: CTR Aggregation BSA/AML
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The fact that an individual owns an entity or signs on an entity's account is not relevant. You are aggregating the transactions because they are "by the same person."

For the individual, check 2a and multiple transactions. List both account numbers.

For the corporation, check 2c. Check "entity." List only the corporate account number.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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