Q: How do I properly complete Part I on the FinCEN CTR for deposits into a joint account? What amounts do we show in Item 21 for each Part I? For example, John and Jane Smith have a joint account together. John Smith deposited $5,000 into the account; later in the same business day, Jane Smith deposited $7,000 into the account.
A: When a deposit is made into a joint account, the deposit is presumed to be made on the behalf of all account holders because all account holders have potential access to the account balance, and multiple Part Is are required. In this example, the financial institution would complete two Part Is. For Item 2 of each Part I, the financial institution would check 2a “Person conducting transaction on own behalf” and complete the applicable information for either John Smith or Jane Smith. Item 21 for each Part I would be completed similarly by entering $12,000 and providing the account number affected.
Note: If Jane Smith did not conduct a deposit, but John Smith deposited $12,000 into the joint account, then in completing Part I for Jane Smith you would check 2c “Person on whose behalf transaction was conducted,” complete the applicable information in Part I for Jane Smith, enter $12,000 in Item 21, and provide the account number affected.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: