Another CTR Question

We have a customer that owns a drug store and also has another business that takes payments for phone bills through the drug store. The phone deposits are always made at the night deposit and the drug store deposit is made in person. The phone payment account is under the individual ssn and the drug store account is the EIN number

This morning when the night deposit was worked, the phone payment deposit consisted of $7,000 in cash. At 10:30 the drug store made deposit which consisted of $5,000.00 in cash. My question is would we file a one CTR showing both businesses as beneficiaries even though one account is the individual's ssn number and the drug store was the EIN?

Why is the drug store under an EIN - is it an actual entity??? Otherwise, for banking purposes, the sole proprietorship's SSN should be used - see the instructions for the W-9.

Without fully understanding the relationship it is a hard question to answer.

Also sounds like they might be an MSB - although I know that was not your question.

I had already reviewed for MSB activity and they are not an MSB. The drug company is incorporated. The separate account is a sole proprietorship. The owner of the drug store is also the owner of the phone payment account. My question was if both accounts make deposits that exceed $10,000 do we file a CTR Deposit on each company doesn't exceed $10,000 but when you add both cash in both accounts they do exceed $10,000.00. One was deposited in person and we do know the person who made that deposit but the one who put the deposit in the night deposit, we do not know who that is.

Review this:

http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-G001.html

Common ownership is not relevant to aggregation.

rlcarey, thanks for your help. The guidance you sent answered our question. Appreciate your help.

To tag on, how do you guys determine when aggregation should occur in common ownership situations?

You use the FinCEN guidance that I posted a link too and make a decision.

I think that after reading that guidance, you'll agree that FinCEN wasn't willing to draw a bright line around circumstances that would trigger your having to aggregate across ownership of separate entities. It's one of those "facts and circumstances" things that FinCEN expects you to figure out based on your knowledge of the customer(s) and their actions.

Analyze the information you have carefully, and obtain whatever additional information you can about the businesses. Then make your determination. Document what you've done, and be ready to defend it if an examiner decides to try second-guessing you.

Thank you!