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Aggregation for BSA Thresholds

Answered by: 
Ken Golliher

Question: 
For the purposes of CTR reporting, does aggregation of multiple transactions include multiple entities? Example: we have an individual who owns three MSB entities, separate tax IDs, different names, and operates in three different towns. Should their cash transactions be aggregated? If so, who goes on Part A of the CTR, the owner and/or all three entities? Another scenario, a customer has a joint account, a corporate account, and is a signer on their child's account. If cash is deposited into all three accounts by one of the joint account holders, an employee of the corporation, and the child into each respective account. Which accounts would be included on a CTR and reported under who's name? If it makes a difference, if you do not know who made each of those three deposits should they be aggregated? Bottom line: how far does aggregation go?
Answer: 

If each of the MSBs is a separate entity; e.g. they are three separate corporations, LLC's (etc.) you do not aggregate their currency transactions based on the fact that they are all owned by the same person. For AML purposes, you would monitor their aggregated activity looking for interrelated transactions, but you would not aggregate their currency transactions unless they were conducted by the same person. In the second example, if the deposits to three separate accounts with different owners are made by three separate people they are not subject to aggregation.

Currency transactions are subject to aggregation when they are made:

  1. by the same person or
  2. on behalf of the same person.



First published on BankersOnline.com 8/14/06

First published on 08/14/2006

Filed under: 
Operations
Filed under operations as: 
Currency
Employee
IT

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