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#1507304 - 02/09/11 05:05 PM W/D from Business Acct How do you write up CTR
mep Offline
Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
If the owner of a business withdrawals over $10,000 from his business account and does not say what he is doing with the money or says that he is going to the casinos with the money, how is the CTR written up?
I say that his name and information goes in section A since either you don't know what he is doing with the money or you know that he is benefiting from withdrawal. If he said he was withdrawaling the money to buy equipment for the business then I would say the business information would go in section A and his information would go in section B.
Please tell me where I can find this in writing but don't send me to the direction that come with the CTR because they are not detailed enough.
Thanks

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#1507349 - 02/09/11 05:31 PM Re: W/D from Business Acct How do you write up CTR mep
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Your assessments are correct. It all depends on who is getting the benefit from the cash. If the individual, he is shown in Part 1 section A and you check box e in section B. If the business, they are shown in section A and the person in section B. On another note, if he is withdrawing cash from the business account to fund a visit to a casino I would consider a SAR.

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#1507358 - 02/09/11 05:37 PM Re: W/D from Business Acct How do you write up CTR devsfan
huezoslb Offline
100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
If he/she is the sole owner of the business, since when is a SAR warranted if he/she states it's for a casino visit? What would be the reason for the SAR?

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#1507377 - 02/09/11 05:50 PM Re: W/D from Business Acct How do you write up CTR huezoslb
mep Offline
Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
I was only using the casino as an example that the money was being used for personal reasons and not for the business.
Where can I find and of this in writing? I have looked everywhere and can find many examples in the regulations and other publications but not one like this.

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#1507390 - 02/09/11 05:59 PM Re: W/D from Business Acct How do you write up CTR mep
huezoslb Offline
100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
Originally Posted By: mep
I was only using the casino as an example that the money was being used for personal reasons and not for the business.
Where can I find and of this in writing? I have looked everywhere and can find many examples in the regulations and other publications but not one like this.


You won't find any of this in writing.

Even if the sole owner decides to withdrawal cash for personal reasons, a SAR is not warranted unless the customer blatantly states that he is going to use the money to buy dope.

If you want to play the CYA game with your regulator, you might want to file a SAR for inconsistent cash activity for type of business, that is if the business is NOT cash intensive.

Other than that, the customer didn't avoid a CTR. I guess it depends who you ask. It's all subjective.

Good luck.

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#1507413 - 02/09/11 06:13 PM Re: W/D from Business Acct How do you write up CTR huezoslb
mep Offline
Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
I think my original question has gotten lost with the mention of the SAR. I want to clairify in writing where to put the customer's name and information on the CTR when he withdrawals money from his business account for person use.
I say just his name goes on the CTR in Section A and the business name and information is not put on the CTR at all.
I just want to find it in writing to refer to.

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#1507445 - 02/09/11 06:30 PM Re: W/D from Business Acct How do you write up CTR mep
huezoslb Offline
100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
here you go.

Items 2, 3, and 4. Individual/Organization Name. If
the person on whose behalf the transaction(s) is conducted
is an individual, put his/her last name in Item 2, first
name in Item 3, and middle initial in Item 4. If there is no
middle initial, leave item 4 BLANK. If the transaction is
conducted on behalf of an entity, enter the name in Item
2 and leave Items 3 and 4 BLANK.
Item 5. Doing Business As (DBA). If the financial
institution has knowledge of a separate “doing business
as” name, enter it in Item 5. For example, if Smith
Enterprise is doing business as MJ’s Pizza, enter “MJ’s
Pizza” in item 5.

http://www.fincen.gov/forms/files/fin104_ctr.pdf

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#1507465 - 02/09/11 06:39 PM Re: W/D from Business Acct How do you write up CTR huezoslb
mep Offline
Junior Member
Joined: Oct 2006
Posts: 41
Bristol, PA
Thanks very much

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