Hello,

We have a business customer who routinely makes cash deposits into business A's (LLC) account in excess of $10,000. From time to time, business A will transfer funds to business B (also an LLC) to pay down on business B's loan and other expenses. No cash deposits ever go into business B but we can tell from our EDD that it appears that business A and business B are not operating independently from each other. Does that mean that business B's information should be included on the CTR? My initial thought is no, but now I am second guessing myself.

Any insight would be much appreciated. Thank you!

If business B ever has cash deposits they should be aggregated with those of business A, a couple pieces of FinCEN guidance confirm that. Since they do not, I do not see any basis for including business B on the CTR. However, if your next reviewer cannot find anything else to write about, he or she may conclude differently. Ask the Helpline. Write down their answer and put it in the file.

No - but if Business B ever deposits cash at the same time as Business A, then you would have to aggregate the deposits for reporting.