Q: When do you check the “Multiple transactions” box (Item 3)?
A: Filers should check “Multiple transactions” (Item 3) if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I. “Multiple transactions” is not the same as the Item 24 option “Aggregated transactions,” which only involves multiple transactions all of which are below the reporting requirements and requires at least one of the transactions to be a teller transaction. The use of Item 24 “Aggregated transactions” is discussed in more detail in FAQ #27.
For example, if Tom Doe deposited $6,000 to his personal account in the morning, and then later in the same business day deposited an additional $5,000 to his personal account, the filing institution would check Item 3 “Multiple transactions” when completing a Part I on Tom Doe. Another example would be if Tom Doe deposited $7,000 into ABC Restaurant’s business account and then later in the same business day Jane Smith deposited $5,000 into ABC Restaurant’s business account, the filing institution would check Item 3 “Multiple transactions” when completing a Part I on ABC Restaurant; however, the filing institution would NOT check Item 3 “Multiple transactions” when completing a Part I on Tom Doe or Jane Smith.
There may be instances where, at one time, an individual brings in funds to deposit to multiple accounts at the financial institution. Whether or not to check “Multiple transactions” in these instances depends on the financial institution’s procedures. For example, a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing as a matter of policy to define each as a separate transaction. When completing Part I on the conductor, the financial institution would check Item 3 “Multiple transactions” as a result of its procedures to post the transactions individually and treat each one as a separate transaction.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: