We have two accounts that are both dba as the same entity. For example, One Entity dba Your Convenience Store in Trust for Money Orders and Another Entity dba Your Convenience Store in Trust for Lottery Funds. There is one individual that signs on both accounts along with other individuals divided between the two accounts. The deposits to the money order account are a mixture of cash and checks, checks only, and cash only with occasional CTR reporting. The deposits to the lottery account are all cash and have not exceeded $10,000. On occasion combined cash deposits of both entities exceed $10,000.

Should these be considered as the same entity for CTR/SAR purposes?

Is the EIN the same on both accounts?

The same business owns two DBAs? If yes, then they are one entity. CTRs should be filed on combined cash.

Two different EINs.

In that case, I believe you would only file a CTR is the same person made deposits to the accounts on the same day and they equalled or exceeded the threshold.
I invite others to correct any errors I made in this assessment. I learn something new every day.

No, two entities apparently own one dba.

I'm also not too sure about one of the EINs provided (begins 33-XXXXXXX). Does anyone know if/how an EIN can be verified?

Thanks

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No, two entities apparently own one dba.

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That, I believe, is impossible.

That's what I thought, but according to the account names it is possible.

I'm was reviewing one account for MSB activity and ran across the second account. The more I look at these two accounts, the more interesting things I find. Both of the two entities (money order and lottery) appear to receive funds from the dba.

Possible CTR and SAR filings based on what I've found so far. Have more information I should look at before I do any filings.

I would be very surprised if these 2 entities have different EINs and are truly separate. I would definitly aggregate the deposits and file CTRs.

To verify the TIN, go to crimetime.com. It will not tell you who it was issued to, but it will verify whether it is valid or not.

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...according to the account names it is possible

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Account names are generally contributed by the customer and, unverified, they offer no proof of existence. In Georgia, you verify the existence of the entity through the Secretary of State's Office and the propriety of the "trade name" through the Clerk of the Superior Court in the county where the business is located.

Your issues cannot be resolved here.

Thanks for all the help on this.

Checked with the SOS office and found that one entity was current but the other had been administratively dissolved.
Visited the crimetime.com site but only found a link for verifying SS#s and not TINs.

Guess the next step is to contact the customer(s) and see what happens. Again, thanks to all who responded.