CTR FAQs - What is the proper way to complete Part I of the FinCEN CTR when different individuals are depositing to the same business account?

Compliance > BSA > FinCEN CTR FAQs
Q:  What is the proper way to complete Part I of the FinCEN CTR when different individuals are depositing to the same business account?
 
A:  Scenario: Bob Smith deposits $6,000 into an account for ABC Hotel. Later in the same business day, Lisa Williams deposits $8,000 into an account for ABC Hotel.
 
The financial institution would complete three Part Is for the above scenario:
  • A Part I on Bob Smith would be completed by 1) checking 2b “Person conducting transaction for another,” 2) completing the applicable information for Bob Smith, and 3) entering $6,000 in Item 21 and providing the account number affected.
  • Another Part I on Lisa Williams would be completed by 1) checking 2b “Person conducting transaction for another,” 2) completing the applicable information for Lisa Williams, and 3) entering $8,000 in Item 21 and providing the account number affected.
  • Another Part I on ABC Hotel would be completed by 1) checking 2c “Person on whose behalf transaction was conducted,” 2) checking Item 3 “Multiple transactions,” 3) checking “If entity,” 4) completing the applicable information for ABC Hotel, and 5) entering $14,000 in Item 21 and providing the account number affected.
 
 
 
ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: 
 

Add Feedback