Thread Options
#2260477 - 09/30/21 01:14 PM CTR Help
compgal21 Offline
Junior Member
Joined: Jan 2021
Posts: 33
Customer A made a deposit into Customer B account in the amount of $14,200. Then, Customer A made another deposit into a savings account in the amount of $1,000 where Customer C is the joint account holder. Should Customer C still be listed on the CTR considering Customer A has brought in $15,200 where Customer C is a benefactor of the one of the two transactions that Customer A conducted or would Customer C not be listed on the CTR due to the fact that there was only $1,000 deposited into that account?

Return to Top
BSA/AML/CIP/OFAC Forum
#2260485 - 09/30/21 01:55 PM Re: CTR Help compgal21
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
"Benefactor" means someone who provides a benefit to someone else. It is not a word that should be associated with CTR filings.

The persons being reported are either a conductor of the transaction or a person on whose behalf the transaction is conducted ("person on whose behalf" for short).

That said, when a CTR is filed, all persons conducting the transactions in the report and all persons on whose behalf the transactions were conducted are included.

Because the $1,000 deposit is included in the report, you must include C as a person on whose behalf that transaction was conducted. I will assume Customer A is the joint owner of the account with Customer C.

Customer A, boxes 2b and 3 checked, $14,200
Customer A, boxes 2a and 3 checked, $1,000
Customer B, box 2c checked, $14,200
Customer C, box 2c checked, $1,000
Last edited by John Burnett; 09/30/21 01:57 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2260486 - 09/30/21 01:59 PM Re: CTR Help compgal21
compgal21 Offline
Junior Member
Joined: Jan 2021
Posts: 33
Yes - Customer C is the joint account holder on Customer A account. Thanks for your help.

Return to Top

Moderator:  Andy_Z