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#1763821 - 12/04/12 08:59 PM CTR Aggregation Question
Auditor31 Offline
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Joined: Sep 2009
Posts: 3
It's been a long day, but here goes...

We have the following customers:

Smith of Texas, Inc. dba ABC Store
Smith, LLC. dba ABC Store

Entities have different EINs and some common authorized signers. These two stores are identical but located in different areas of the city. Should deposits to these accounts be aggregated for CTR purposes? Thanks in advance!

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#1763827 - 12/04/12 09:08 PM Re: CTR Aggregation Question Auditor31
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Here's the information you'll need to make that decision:

Guidance (FIN-2012-G001) – Currency Transaction Report Aggregation for Businesses with Common Ownership (03/16/2012)

Unfortunately, this isn't a black and white response to your question. You have to review the guidance and decide whether to aggregate based on your understanding of the actions of your depositors.
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John S. Burnett
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