I was told by our auditor that personal accounts can’t be used to conduct business transactions and if it happens, a SAR should be filed. Is this correct?
We have a joint account for a sole proprietorship that is owned by a husband and wife as a DBA, but for tax purposes the business is filed under the wife's TIN. Should the DBA be listed in Part I, Section A, #5 for both the wife and husband on the CTR form or just the wife?
I received a bank execution against an individual. The only account we had was a sole proprietorship using the individual's Social Security number. Everything I read tells me the individual is responsible for business debts, but is the opposite true?
I have recently moved into the compliance area at our bank. The previous compliance officer revoked CTR reporting exemptions for sole proprietorships. Is there anything in the regulations that prohibits us from granting an exemption from CTR reporting requirements to a sole proprietor?
Is a CTR required if there was less than $10,000 in cash deposited into a personal acct and less than $10,000 in cash deposited into that individual’s business acct, which has a different Tax ID, but together they total over $10,000 in a single day? Would it only be required if we knew the deposits were brought in by the same conductor?
Document Alteration Techniques...continued
Substance Abuse & Addiction Forgeries
Our CIP policy states that for a sole proprietorship, we CIP only the owner following our consumer CIP procedures. Our consumer CIP procedures permit account opening for a non-resident alien without a TIN, and with a signed W-8. What are the requirements if a non-resident alien wants to open an account for a sole proprietorship? Do we not open the account if the owner does not have a social security number?
If a deposit in excess of $10,000 in cash is being deposited into a sole proprietor/business account by the proprietor himself, and there are additional signers on the account, do the additional signers have to be included on the CTR?
The bank has a customer with two separate business accounts. One is a sole proprietorship mini-mart; the other is a corporation with a separate EIN. He frequently deposits money into these accounts, which when aggregated together totals over $10,000. However, when treated separately, they do not total over $10K. His business accounts are exempt. Should he remain an exempt customer when he rarely deposits over $10K in each account? Should we file a CTR on him (personally) for the cash transactions over $10K, even though they are for his business?