CTR Filing on a Two Owner Business

Answered by:

Question:

If you have a business that has two owners and each owner comes in (one owner withdraws $11,000 and the other withdraws $8,000) at different times on the same business day would you list this as a multiple transaction in Section B on FinCen Form 104 to show the total amount withdrawn or is there another way this type of transaction should be filed?

Answer:

First, you need to determine who benefits from the transactions. If the business is benefiting from both withdrawals, you file a CTR naming the business in Section A and including two separate Section B entries (one for each of the two owners, who conducted the transactions). If the individuals are the persons benefiting from the withdrawals, no CTR should be filed. If it's apparent to you that the business is the beneficiary, you should also refer the transactions to whoever in your bank deals with SAR filing, unless there is a business reason for the two transactions to be separate.

First published on BankersOnline.com 11/19/07