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#1089811 - 12/01/08 07:40 PM CTR Question
mkp122 Offline
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NJ
We have three different accounts with the same address appearing on our large cash transaction report aggregating over $10,000. All accounts are single ownership and it appears that the transactions were conducted by three different people. I'm investigating for a possible SAR filing but do we need to complete a CTR based on the fact that they all have the same address?

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#1089814 - 12/01/08 07:42 PM Re: CTR Question mkp122
Skittles Online
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Skittles
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TN
No, they need to have the same Tax ID number in order to be combined - or the same conductor.
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#1089973 - 12/01/08 10:23 PM Re: CTR Question Skittles
devsfan Offline
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I also suggest that you monitor the accounts to see if the deposits are consolidated into 1 of the accounts. There was a FinCEN guidance letter covering this scenario from 2001 or so that concluded that a CTR should be filed in this case.

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#1089986 - 12/01/08 10:42 PM Re: CTR Question devsfan
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By: devsfan
I also suggest that you monitor the accounts to see if the deposits are consolidated into 1 of the accounts. There was a FinCEN guidance letter covering this scenario from 2001 or so that concluded that a CTR should be filed in this case.


http://www.fincen.gov/news_room/rp/rulings/html/fincenruling2001-2.html
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