Have an individual who owns an S-Corp Trucking company, as well as an LLC that operates convenience stores. For quite some time, individual has made cash deposits in excess of $10k to the deposit account of the trucking company. We believe that the money is actually the cash receipts from the convenience stores. The trucking company is a struggling business, and in addition to the cash being deposited into the trucking company's account, he also makes internet banking transfers from the LLC deposit account to the trucking account to cover overdrafts. With the operation of several convenience stores, the cash deposits exceeding $10k ends up being two to three times a week. We have filed CTRs in the past, but would like to exempt from this filing. We do not believe there is any money laundering or illicit activity. Is there any problem with exempting the trucking company, since that is the account to which the cash is being deposited? We have been preparing and filing multiple CTRs every week for over five years. We just do not see the benefit of having to continually file the CTRs, or the benefit/need of the government for these CTRs.

You cannot exempt a company if they are not generating the cash that they are depositing. How are you going to: if the bank undertakes a risk-based analysis of that customer that allows it to form and document a reasonable belief that the customer has a legitimate business purpose for conducting frequent large currency transactions?

I would have a conversation with the customer to confirm your suspicions. If the cash is from the convenience store, then they should be depositing it to the convenience store account.

Consider a more egregious case.

I deposit cash from my MSB money transmission business into my trucking business. You exempt my trucking business even though the source of cash is from ineligible activity claiming that the trucking business is not an ineligible business type.

There's all kind of risk here for evading taxes and suspicious activity monitoring processes. Exempting from CTRs would only compound those concerns.