We have a handful of Limited Partnerships (each with their own EIN) which are held under an LLC. The LPs collect income from servicing rental properties and mortgages in several different cities (seems to be one LP per city). The LPs do not comingle funds, but they do each transfer quarterly "management fees" to the LLC which pays out operating expenses and payroll. There are a handful of employees that are paid by the LLC which are used between all entities - they do bookkeeping and bring in deposits. No individual LP or conductor exceeds 10k.

Would the fact that there are only a few employees working for multiple entities be enough to aggregate transactions for CTR purposes?

The guidance from FinCEN states examples including "the businesses are staffed by the same employees and are located at the same address, the bank accounts of one business are repeatedly used to pay the expenses of another business, or the business bank accounts are repeatedly used to pay the personal expenses of the owner". These are small operations so we don't believe they have an "office" per se. Other than the distributions, they're not sharing expenses directly. They're just using the same employees, paid by the LLC, to service all of the accounts.

If they are all separate legal entities and there is no evidence that they are comingling funds, I see no reason to have to aggregate them, regardless of the common ownership or the same employees.

I was leaning this way as well but was hung up on the guidance's example of sharing employees. With smaller entities like this, it's not unreasonable for their employer to have them conduct multiple jobs.

I appreciate the response!

Shared employees is one symptom, but by itself I would not automatically decide the businesses aren't operated independently.