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CTRs and Joint Accounts

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Question: 
I know this question has been asked before but I'm having issues with explaining this to one of our Financial Managers. When a reportable cash transaction is made into a joint account, we need all the joint account owner's information in order to complete the CTR for filing. Am I correct?
Answer: 

If the transaction is a deposit that includes a reportable cash amount, yes, you include a Part I for the CTR for each joint account owner, checking box 2c to show him/her as a person on whose behalf the transaction was completed (if an owner of the account is the conductor of the transaction, his or her Part I shows that the transaction was made on his/her own behalf (box 2a is checked).

You should have sufficient information on each owner to provide his/her name, street address, date of birth, and identifying number (SSN for U.S. persons), assuming the account was opened on or after October 1, 2003 (when the CIP rule went into effect).

If the transaction is a withdrawal or the cashing of a check drawn on the joint account, you do not need to a Part I for each co-owner other than the conductor of the transaction UNLESS you have knowledge that the transaction was also being conducted on behalf of one or more of the co-owners. If you do not have such knowledge, you are neither required to nor prohibited from listing the co-owners other than the conductor. [FinCEN FAQ Regarding the FinCEN Currency Transaction Report (CTR), Question 24, as of October 3, 2019, viewed May 20, 2024]

First published on 06/16/2024

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