John Smith comes into the bank and makes a $4K cash withdrawal from his personal checking and an $8K cash withdrawal from his business checking, John Smith's Towing.

John states to the branch staff that both cash withdrawals are being conducted to purchase equipment for John Smith's Towing.

Is John Smith conductor AND beneficiary for the $4K cash withdrawal from his personal account even though he stated that the $4K was being withdrawn for the benefit of John's Smith's Towing? Or is he just the conductor for the purposes of this whole CTR?

Thank you!

If this is a sole prop, he's conducting on his own behalf. He is not separate from his business.

Not a sole prop. One account is a personal checking and the other account is a business checking. But he stated at the time of the transaction that both withdrawals were for purchase of business equipment.

I would fill out two part I's; one for John Smith conducting $12,000 withdrawal on behalf of someone else, and another for John Smiths Towing for $12,000, listed as the person on whose behalf the transaction was conducted.

If "John Smith's Towing" is not a sole proprietorship what is it?

It's a towing company, silly! (I could not resist that.)

Cape Codder's question simply points out that the fact that the towing company has a business checking account doesn't mean it's not a sole proprietorship. If it's not a sole proprietorship, is it an LLC, a corporation, a partnership? You (BSAN3rd) need to know if the trucking company is a legal entity separate from John Smith to complete the CTR correctly.

Thanks, John. I needed that chuckle today!!

Sorry about that. To clarify, it would be John Smith and John Smith's Towing Company, LLC. A personal account for John Smith and a business account the separate legal entity, John Smith's Towing Company, LLC. But John Smith is stating that all funds (from his personal and business accounts) will be used for the benefit of John Smith's Towing Company, LLC equipment purchases.

So John is the conductor and the LLC is the beneficiary on the CTR, based on the statement from your customer.

Agreed.