CTR for multiple companies

We are having a discussion about a group of corporations with the same signers and different EINs. If each company makes cash deposits under $10,000.00, but the aggregate amount of all the companies exceeds $10,000.00 is a CTR filed? We cannot determine if the same person is making the deposits and they are all at different brancheds. I say no CTR, because each corportion is the beneficiary of the funds not the signers. Am I correct?

Each entity is a different person. Banks are required to aggregate if transactions are by the same person. They are also required to aggregate if transactions are on behalf of the same person.

Two entities with the same owners and signatories are not the same person. Their transactions are not subject to aggregation.

There is FinCEN guidance to the effect that if the entities are not operated separately; e.g. transfers are made between them to cover payrolls etc. then their transactions might be subject to aggregation. That's the exception, not the rule.

You only aggregate if the same person is conducting the deposits or if you have knowledge that the different businesses are not being operated independently and thay are co-mingling their funds (see FinCEN ruling 2001-2). In your case it would be nice to be able to identify the conductors.

Thank you!