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Required to List Business Signers if They Benefit?

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Do business signers need to be listed on a CTR as benefiting from a transaction?

No. A deposit to a corporation, LLC, partnership, etc. is not made on behalf of the signatories to the account. They do not "benefit" from the transaction in any way regardless of whether they do or do not have an ownership interest in the entity. In the case of a withdrawal, it would be appropriate ask the person conducting the transaction if the withdrawal is made on his or her behalf or on behalf of the entity.

In the case of a sole proprietorship, all transactions are on behalf of the individual owner, not any signatories who may be on the account.

First published on 2/4/13

First published on 02/04/2013

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Filed under compliance as: 

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