CTR FAQs - I am filing the FinCEN CTR on an entity; however, the selections in Item 2a-2c all reference a person. What selection would I choose when filing on an entity?

Compliance > BSA > FinCEN CTR FAQs
Q:  I am filing the FinCEN CTR on an entity; however, the selections in Item 2a-2c all reference a person. What selection would I choose when filing on an entity?
 
A:  Under the BSA regulations, the definition of “person” found at 31 CFR 1010.100(mm)   is “an individual, a corporation, a partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture, or other unincorporated organization or group, an Indian Tribe (as that term is defined in the Indian Gaming Regulatory Act), and all entities recognizable as legal personalities.” Since an entity cannot physically conduct a transaction, the only selection that would apply is 2c “Person on whose behalf transaction was conducted.” In addition, if filing on an entity, a filer must select the checkbox (Item 4b) for “If entity” in Part I.
 
 
ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: 
 

Add Feedback