Ok - please bear with me - I have been out sick and may not be thinking clearly.
Business account - one principal "A" comes in at 12:40 and withdraws $6000 from the business account. At 3:15 (same day) another principal "B" comes in and withdraws $5,000 from the same business account. A CTR generated showing "B" as the "Person on Whose Behalf Transaction is Conducted" for $11,000 and the negotiable instruments cashed box is checked.
I am thinking, two different people (A and B), although related (husband and wife) withdrew cash under the reporting threshold from the account at different times. I don't think I need a CTR but really a SAR (unless there is a reasonable explanation). Am I missing something? The CTR wouldn't be under the business name because the business didn't walk out with cash the individuals did, right?