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#2218206 - 07/23/19 03:49 PM CTR multiple conductors
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,055
Compliance Land
My head hurts on this one:

Husband and wife own three businesses A, B & C. Yesterday, wife comes in and withdraws:

$11,000 cash from A,
$1,000 cash from B and
$1,000 cash from C and
$1,000 cash from her personal account

Husband comes in later that same day and withdraws:

$1,000 cash from his personal account and
$10,000 cash from business A's line of credit

How in the world do I complete these CTR(s)? smile
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#2218208 - 07/23/19 04:03 PM Re: CTR multiple conductors Red Raiders
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Total cash out $25,000; Multiple transactions; multiple conductors (husband and wife) and multiple beneficiaries (husband and wife).

I don't know your customer, but is this normal? Do you have a reasonable explanation for all of this cash being withdrawn? You could be looking at filing a SAR too.
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David Dickinson
http://www.bankerscompliance.com

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#2218218 - 07/23/19 04:49 PM Re: CTR multiple conductors Red Raiders
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,055
Compliance Land
Would all businesses get listed in the CTR?

Nothing shady going on. Long story!
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#2218277 - 07/24/19 03:07 PM Re: CTR multiple conductors Red Raiders
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
Originally Posted by Red Raiders
Would all businesses get listed in the CTR?

Nothing shady going on. Long story!


Were the withdrawals done on behalf of the business(es). on behalf of the individuals, or both? That's how you decide whether the businesses get included.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2218354 - 07/24/19 08:20 PM Re: CTR multiple conductors Red Raiders
Red Raiders Offline
Diamond Poster
Red Raiders
Joined: May 2013
Posts: 1,055
Compliance Land
The husband and wife were just trying to pull out as much money as they could before the other one got to it. #divorcelooming
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