How would you file a CTR for the following scenario:

On 5/10/21 after hours, an individual withdraws $6,100 on behalf of business which is an LLC. The next day he comes back to the bank and withdraws another 5,000 from the same LLC and then he also withdraws another $2,500 from a dba account which is in his name. So the gentleman withdrew a total of $13,600 in cash on 5/11/21.

Would you file a Part I on LLC for the $11,100 as a 2c; a Part 1 on individual as dba for the $2,500 as a 2a and then another Part 1 on the individual as a 2b for the $11,100 or a 2b for the $13,600.

Let me know.

Thanks for your help.

How does someone withdraw cash after hours?

What I mean is after the close of business (processing) for that day (5/10/21), the institution remains open for a few more hours to accept transactions but those transactions do not get processed until the next business day (5/11/21).

Oh OK. I didn't know cutoff hours was still a thing.

I think your Part I's are just the LLC and the individual. $11100 for LLC, and $13600 for the individual with the two different account numbers. You can add the DBA name to individual's listing. A DBA is not its own entity.

This is how we would file it.

What about the FINCEN notice 10/1/2019 where FINCEN notified filers of an issue that was identified with the CTR instructions involving how to file a CTR when an individual subject has multiple Part I item 2 roles that was updated with a mandatory effective date of 9/1/2020?? Would this not apply in this scenario??

Bjet, the new requirements do apply. You will have three Part I's

LLC - 2c $11,000
Individual - 2a $2,500 (include DBA in the alternate name field)
Individual 2b $11,000

Check multiple transactions for all Part I's since both the individual and the LLC were involved in more than one transaction.

Thank you, appreciate your help!!