Q: What if more than one “role” (Item 2) applies to the person being listed in Part I?
A: If more than one Item 2 option applies to a person involved in the transaction(s), filers should complete only one Part I on that person with only one entry in Item 2 pursuant to the following construct:
When to select Option 2a: In addition to when only Option 2a applies, filers should select Option 2a “Person conducting transaction on own behalf” if 1) Options 2a, 2b, and 2c apply; 2) Options 2a and 2b apply; or 3) Options 2a and 2c apply.
When to select Option 2b: In addition to when only Option 2b applies, filers should select Option 2b “Person conducting transaction for another” if both Options 2b and 2c apply and Option 2a does not apply.
When to select Option 2c: Filers should select Option 2c “Person on whose behalf transaction was conducted” only on the person for whom the transaction is conducted. This person cannot have other roles within the transaction or the options would apply.
When to select Option 2d: In addition to when only Option 2d applies, filers should select “Courier Service (private)” if multiple options that include 2d “Courier service (private)” apply.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: