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#2254347 - 05/25/21 02:56 PM CTR or SAR or both
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
Husband and wife each bring in $10,000 to deposit to two different accounts with both names on them, and three days prior had deposited had deposited $7700.00 - it is believed they are structuring too avoid the reporting - so should CTR be filed for the two deposits and then a
SAR be filed for the combination or just a SAR for all

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#2254351 - 05/25/21 03:07 PM Re: CTR or SAR or both Compliance Action Subscriber 1226
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
Deposits are assumed to benefit all accountholders, so if they made the $10,000 deposits on one business day, then a CTR is required. I think a SAR is in order.
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#2254352 - 05/25/21 03:34 PM Re: CTR or SAR or both Compliance Action Subscriber 1226
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,796
You are here
"it is believed they are structuring too avoid the reporting -"

SAR would be required.

"10,000 to deposit to two different accounts with both names on them"

CTR required as well
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#2254401 - 05/25/21 08:16 PM Re: CTR or SAR or both Compliance Action Subscriber 1226
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
When H and W each makes a cash deposit to an account or accounts jointly held by H and W, and those deposits aggregate to more than $10,000 you will have a CTR with FOUR part I entries -
1. H as conductor with items 2a and 3 checked, with total of the deposits H conducted
2. W as "person on whose behalf" with items 2c and 3 checked with total of the deposits H conducted
3. W as conductor with items 2a and 3 checked, with total of the deposits W conducted
4. H as "person on whose behalf" with items 2c and 3 checked with the total of the deposits W conducted
Item 25 will show the total of the cash deposited.
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