CTR Required for Deposit In Business & Joint?

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Question:

We have customers with a joint checking account and they are also signers on a business account. One day, Mrs. Customer deposits $4000 cash in the joint account. On the same day, Mr. Customer deposits $7000 cash in the business account. CTR required?

Answer:

Assuming the business is an entity, the two transactions were not conducted by the same person nor were they conducted on behalf of the same person. They are not subject to aggregation on a currency transaction report.

First published on BankersOnline.com 11/19/12