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The Owner, the Employee and the CTR

Do we have to file a CTR in the following situation? The owner makes a deposit into his business account in the amount of $9,800.00. Later that day, one of his employees comes in and obtains coin order in the amount of $500.00. Are we to assume that the coin order is done on behalf of the business, and file a CTR for the total of $10,300.00?

Answer by Richard Insley: You don't aggregate cash-ins with cash-outs to determine coverage of the CTR filing rules.


Answer by John Burnett: However, if the coin order took the form of a currency exchange (the change was purchased with cash), you have two cash-ins for the day totaling $10,300 and you have a CTR to file with two entries in Section B. You don't list the cash-out portion of the coin order on the CTR.


Answer by Richard Insley: I agree.

First published on 3/27/06

First published on 03/27/2006

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