John Doe owns 3 different stores. A store clerk of one of the businesses made all the deposits with one teller at one time. All three of the organizations are operated independently of one another:
- A corp. acct. # 12345 had a cash-in total of $5,000.
- B corp. acct. # 54321 had a cash-in total of $5,000.
- C corp. acct # 98765 had a cash-in total of $5,000.
How do I complete the multi-account, multi-business CTR? Specifically, how many Part I’s are involved and how do I handle the cash-in figures?
The bank would complete four Part I’s – one for the store clerk who conducted the deposit; and one for each of the corporations (A, B, & C) where the deposits were made, as the deposits in this scenario are on behalf of each entity. As for the “Cash in amount,” the total $15,000 would be included on the store clerk’s Part I, and $5,000 would be listed for each entity. This is because the instructions refer to the person/entity listed in #4(Individual’s last name or entity’s legal name) in respect to Cash-in. Since you have separate Part Is, each Part I would be specific to the person/entity listed in #4. Further, because the businesses are independent of each other, this guidance implies (by reverse implication) that option A would be incorrect:
“…Because of this information, the bank has determined that Company A and Company B are not independent of each other. One day, an employee of Company A deposits $6,000 into the account of Company A. That same business day, an employee of Company B deposits $5,000 into the account of Company B. Because the bank has determined that the businesses are not independent of each other, the bank should file a CTR listing Company A and Company B in separate sections identifying the person(s) on whose behalf the transaction is conducted and listing a cash-in deposit of $11,000. The remaining sections of the CTR should be filled out according to the form instructions.”https://www.fincen.gov/resources/statutes-regulations/guidance/currency-transaction-report-aggregation-businesses-common
Finally, multiple transactions should only be marked for the conductor and not the businesses, because – like the Cash in amount – the Multiple transactions box relates to the person listed on the Part I, and here – the only person involved in “multiple transactions” is the clerk (conductor).
- Cash in amount for individual or entity listed in item 4 a. Acct. number(s) included in item 21 Item 21 Cash in amount: Enter the total cash in amount denominated in U.S. Dollars that was transacted by or for the person recorded in Item 4. This amount cannot be greater than the amount in Item 25 “Total cash in.
FinCEN, CTR Electronic Filing Instructions, p. 97:https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf
Another example would be if Tom Doe deposited $7,000 into ABC Restaurant’s business account and then later in the same business day Jane Smith deposited $5,000 into ABC Restaurant’s business account, the filing institution would check Item 3 “Multiple transactions” when completing a Part I on ABC Restaurant; however, the filing institution would NOT check Item 3 “Multiple transactions” when completing a Part I on Tom Doe or Jane Smith.
FinCEN, CTR Frequently Asked Questions, #18:https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
Multiple transactions” (Item 3) if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I.
FinCEN, CTR Electronic Filing Instructions, p. 94:https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf
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