I'm 99% certain that everything is kosher with the way we've been handling the situation on the accounts that I'm going to discuss, but I've talked myself into having some nagging doubt and I'd like a little clarification/reassurance if possible.
ABC, Inc. owns several Alice's Restaurant franchises. ABC, Inc. has opened 2 accounts with my institution - Account # 100001 , ABC, Inc. DBA AR # 1 and Account # 100002, ABC, Inc. DBA AR # 2. Every weekend the two restaurants deposit, in aggregate, a CTR reportable amount of cash. Here are my questions:
1) It was correct to aggregate these transactions for CTR purposes since they were on behalf of ABC, Inc., wasn't it?
2) Assuming that it was correct to aggregate the transactions made on behalf of ABC, Inc., and given that they're not ineligible for a Phase II exemption, the fact that the deposits are being aggregated from different physical locations doesn't make them ineligible for exemption, does it?
3) Assuming that all deposits were night deposits, should the CTR have had two Part I forms - one that read ABC, Inc. DBA AR # 1 - 123 Maple Street and another that read ABC, Inc. DBA AR # 2, 789 Oak Street?
Second situation.....
I'm reviewing my exemption list.
Damage, Inc. has been an exempt customer for many, many years. They have one account that reads Damage, Inc. DBA Orion # 1. I start to look for five transactions. I see that their three deposits come from three different stores (at least based on the different store numbers on the deposit tickets). They are all the same type of stores (Orion # 1, Orion # 2, and Orion # 3). Damage, Inc. has chosen to have these three retail outlets make deposits into the same account. I have asked my predecessor as BSA Officer if she can tell me where the stores are located and she doesn't know. Here is what I'm curious about:
1) Since all deposits are on behalf of Damage, Inc., they're still going to be eligible for exemption, aren't they? (This is similar to my question above.)
2) How much noise should I make to learn about the different store locations?
The account activity is reasonably mundane. It's cash-intensive, but expectedly so.
Thanks in advance for any advice and suggestions.
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