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Proper Way of Reporting Beneficiaries (BSA/AML)

Question: 
What is the proper way of reporting the beneficiaries of the following cash in deposits in a CTR. The TIN number for all is the same #11-1111111. XYZ Corporation (6 accounts*) $11100 XYZ Corporation dba Café,LLC (Acct 9999) $1000 XYZ Corporation dba Bake LLC (Acct 888) $600 * There is no dba in the title of the 6 accounts. Do I need to report 3 beneficiaries to show the actual amount of cash deposited to the accounts? Is it okay to report XYZ Corp dba Café LLC (6 accounts including acct #9999) $12100 and XYZ Corp dba Bake LLC (acct #888) $600?
Answer: 

by Brian Crow

There is only one entity on whose behalf the transactions were conducted, XYZ Corporation. Report a single Part I for XYZ Corporation listing the two alternate names in item 8 separated by semi-colons. List all eight accounts in item 21 with a total dollar amount of $12,700.00.

Answer: 

by John Burnett:

I respectfully disagree with my friend Brian.

If the two LLCs are independently operated, you do not aggregate their cash activity with each other or with XYZ. Legally, a corporation can't "DBA" an LLC, but I suspect you've set the account up that way so you could tie them to the XYZ TIN. For CTR purposes, you should treat the two LLCs as separate entities unless they are not operated independently from XYZ.

If you treat them separately, the deposits into the two LLC accounts are not reported at all (unless conducted by the same person conducting the XYZ corporate deposits). The $11,100 in cash deposits is reported for XYZ Corp.

Answer: 

by Brian Crow:

Thanks, John.

I got to "dba" and stopped reading and missed the LLC that followed.

First published on 12/20/2015

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