Posted By: BSA/AML
CTR Aggregation - 02/20/15 03:53 PM
We have a customer who owns a convenience store that also sells lottery tickets and is cash intensive. We usually do about 1-2 CTRs on this customer a week. He is the sole owner of the business and the only signer on the business checking account. He also has a personal checking account in which he is the sole signer on. When he brings in the cash for his business he also makes a small cash deposit into his checking account. When filing CTRs for on the customer I have been putting both he and the business as the entities on whose behalf the CTR is being filed and checking off the Multiple transactions and conducted on own behalf boxes. To review these cash transactions I check a large cash transaction report (Anything over $5,000.00)that pulls information based on account number and a daily cash report that pulls information based on the TIN number. Is this correct or should I be filing based on the customer since he is the sole owner of the business?