Skip to content
BOL Conferences Top Gun 23
Thread Options
#2257611 - 08/03/21 07:53 PM CTR?
Curious in Kansas Offline
Member
Joined: Oct 2015
Posts: 71
We have a customer who has a business account of ABC Restaurant with an EIN. We have another customer who has a business account of ABC Restaurant using a social as the TIN because its being used as a DBA.

In the night drop, we had the following (no conductor):

ABC Restaurant with an EIN deposited $6,245
ABC Restaurant with a social being used deposited $5,929
Total $12,174

Our system aggregated the transactions where it shows we need a CTR but I don't think we do. While they are the same entity, they are two separate tax ID numbers.

Is a CTR needed in this situation? I think the answer is no.

I've completely overthought this and have managed to confuse myself.

Return to Top
BSA/AML/CIP/OFAC Forum
#2257622 - 08/03/21 08:39 PM Re: CTR? Curious in Kansas
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
While they are the same entity, they are two separate tax ID numbers.

What does that mean? One is an actual business entity and one is a sole prop DBA the restaurant? How can the same entity operate as both?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2257633 - 08/03/21 09:20 PM Re: CTR? rlcarey
Curious in Kansas Offline
Member
Joined: Oct 2015
Posts: 71
Same business name (common fast food chain) but two different stores and two different ownership types.

Return to Top
#2257637 - 08/03/21 10:02 PM Re: CTR? Curious in Kansas
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
Then they are totally unrelated transactions and whatever in your system is linking them together should be turned off.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2257738 - 08/05/21 06:08 PM Re: CTR? rlcarey
Curious in Kansas Offline
Member
Joined: Oct 2015
Posts: 71
Thank you.

Return to Top

Moderator:  Andy_Z