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#2252124 - 04/09/21 06:17 PM CTR help
J_G Offline
Gold Star
Joined: Dec 2010
Posts: 261
I need some help completing a CTR please.

John Doe made 2 cash deposits. One of them ($169) was on his personal account, and one of them ($18,855) was on his business account that he is also a signer on. I am confused on how to complete the CTR.

So I assume I put John Doe and the XYZ Inc as the 2 subjects in the CTR. Do I mark "Person conducting transaction on own behalf" for him, and just enter his account # and the $169 deposit in his section? Do I need to enter him in 2 sections since he is also "conducting transaction for another"?

Do I mark "multiple transactions" in each subject's section? I am confused how to do this... please help. Thank you.
Last edited by John Burnett; 04/12/21 03:18 PM. Reason: changed SAR to CTR is third paragraph.
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#2252135 - 04/09/21 08:40 PM Re: CTR help J_G
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 236
I would file the CTR with
John Doe - conducted on own behalf with the personal account # and the $169 deposit
John Doe - conducted on behalf of another with the business account # and the $18855 deposit
XYZ Inc. - person on whose behalf transaction was conducted with the business account # and the $18855 deposit

My system will check off "multiple transactions" for John Doe automatically.

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#2252136 - 04/09/21 08:59 PM Re: CTR help J_G
JackieW Offline
New Poster
Joined: May 2019
Posts: 20
in the latest FinCEN CTR instructions, it give this as an example on pg 96 of how to record a transaction which fits your situation. "For example, if the Part I person conducted a $5,000 deposit into their personal account and a separate $7,000 deposit into the account of another person/entity, there will be one Part I on that person reporting option 2a on the personal deposit with that amount and account number in Item 22 “Cash in amount…”. There will be a second Part I on that person reporting option 2b on the person/entity account transaction with that amount and account number in Item 22."

In regard to checking multiple transactions, pg 96 says, "Item 3 Multiple transactions: Check Item 3 if multiple cash transactions of any amount totaling more than $10,000 as cash in or more than $10,000 as cash out (cash in and cash out transactions should not be combined) were conducted in a single business day by or for the person recorded in Part I." In your example, two transactions were conducted by the same person and they total more than $10,000 so you would check multiple.

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#2252142 - 04/09/21 10:18 PM Re: CTR help J_G
J_G Offline
Gold Star
Joined: Dec 2010
Posts: 261
Thank you both very much.

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