I recently called FinCEN regarding something extremely similar, and they stated to me that all withdrawals from a business account are to be considered for the benefit of the business unless explicitly stated otherwise. Going off that guidance (which I'd certainly advise you to call independently as well to ensure that you're getting the guidance straight from FinCEN for documentary purposes), Jake would be your conductor, and ABC Inc would be your beneficiary, as there was nothing noted in your post regarding the necessity for the funds, so you are to assume it's for the benefit of the business.
A little confused by the second part...in what context would you be adding more people to the CTR if the tellers aren't sure?
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