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CTR Scenario-Deposit in 2 Different Accounts

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Question: 
I have a CTR scenario that I need guidance on: John Doe comes in and deposits $10,500 in cash into two different accounts. He deposits $9000 into an account that he owns by himself. He deposits $1500 into an account that he jointly owns with his girlfriend Jane. Does a Part One need to be filled out on the girlfriend Jane?
Answer: 

The rule is that a CTR must be filed when cash transactions of more than $10,000 are completed by or on behalf of a person.

Once it's determine that a CTR must be filed, you need to include all of the cash transactions in or out conducted by or on behalf of that person (those persons).

And, if a transaction is included in a CTR, the conductor (when known) and each person on whose behalf the transaction was completed must be identified.

Jane is a person on whose behalf the $1,500 cash deposit was made. That deposit is included in the CTR because it's one of the transactions conducted by John, who completed cash-in transactions totaling $10.500.

Therefore, a part one section for Jane must be included in the CTR.

First published on 08/02/2020

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