Okay - so basically both checks were for the business to use, so you would combine the transactions and file a CTR. It would be different if one was a paycheck to an employee who cashed the check for his/her self and then the other check was simply petty cash for the business.
Having said that, it's stuff like this that shows how antiquated the entire CTR filing process is. It takes more time to complete a CTR than it does to complete a 1040A tax return. The process needs to be brought up to date for banks to file, on a monthly basis, a report of all cash-in and cash-out transactions per account, above a pre-selected aggregate amount. The whole notion of "conducted by" and "conducted on behalf of" is just noise. It would be the one potential useful result of the whole Beneficial Owner mess - the report would include account number, account name, physical address, TIN, and Beneficial Owner and Control Person information.
Then LE can comb the database to their hearts content looking for aggregate activity across multiple institutions (because let's face it, the more sophisticated criminals will run money through various institutions, not just one) and then institutions can focus their resources on CDD/EDD and monitoring activity rather than the painful exercise of which friggin' box to check on a CTR.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'