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Cash Transaction More Than 10K For a Joint Account

Answered by: 
John Burnett

Question: 
I have a CTR question I have yet to see posted anywhere. Any cash transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
Answer: 

Although Suzy conducted cash deposits of $10,000 and John conducted a cash deposit of $1,000, because all three accounts are jointly owned by Suzy and John, the three deposits totaling $11,000 were completed on behalf of both Suzy and John, and that requires a CTR.

Here's where the fun starts. You will need four (yes, four) Part I sections.
Part I for Suzy as conductor on her own behalf, with items 2a and 3 checked for the two $5,000 cash deposits to the joint accounts A & B.
Part I for John as person on whose behalf those two cash deposits were made, with 2c and 3 checked.
Part I for John as conductor on his own behalf, with item 2a checked for the $1,000 cash deposit to joint account C
Part I for Suzy as person on whose behalf that deposit was made, with item 2c checked.

First published on 01/21/2024

Filed under: 
Compliance
Filed under compliance as: 
BSA
SAR

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