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Reporting a cash deposit and currency exchange

Question: 
John Jones makes a cash deposit of $9,600 to the account of his hardware store, Jones Hardware, Inc. He also gives the teller five $100 bills and obtains $500 in $20 bills in exchange. Is there any change to how we will report these transactions?
Answer: 

No. The “old” instructions would have you complete a conductor (2a) Part I on John Jones and a “personal on whose behalf” (2c) Part I on Jones Hardware, Inc. Both Part I entries would have item 3 (Multiple transactions) checked (John conducted both transactions on behalf of Jones Hardware, Inc.). The “cash-out” side of the currency exchange won’t be reported. The revised instructions for Item 3 haven’t changed that.
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Learn more about John Burnett’s webinar FinCEN’s new CTR instructions

First published on 03/15/2020

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