In reviewing our daily keyboard transfer log, it was found that a loan payment was transfered out of an LLC account with a EIN number in to Loan that is in the name of one of its members and has a TIN number.

Is there a BSA ruling that addresses the transfer of funds and different EINs?

No, this really is not a BSA issue.

There have been many prior threads in other forums regarding whether transfers should be allowed among accounts that do not have the same ownership. In my opinion, the only defensible approach is to limit transfers to accounts that are owned in exactly the same right and capacity. See what your bank's policy is and whether or not it was followed in this instance.

Do not rely on TINs for any decision making.TINs assigned to different accounts are only as reliable as the bank employees who accepted them. That makes them inherently suspect. If an LLC has a single member, it may have an SSN or an EIN. An LLC with multiple members will always have an EIN. So, look at your account documentation to see if the LLC is a single or multi-member entity. If it's a multi-member LLC you are going to consider contacting the other member(s) and filing a SAR.

My company is an multi member LLC. My partner would have the right to question the validity of any payment made from the LLC account to a loan that only I owed.

Yes it is a multi-party member LLC. We do not allow transfers between accounts with different EINs or SSA, but somehow this one got under our radar for awhile.

Then I suggest you permanently disrupt the connection between the accounts and ask the members about the specific transaction when you do so. Their reaction may tell you whether a SAR is necessary...