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FinCEN Guidance: CTR Aggregation for Businesses with Common Ownership

FinCEN Guidance: CTR Aggregation for Businesses with Common Ownership
Generally speaking, a financial institution must aggregate multiple currency transactions if it knows that the transactions are by or on behalf of any person and result in either cash in or cash out totally more than $10,000 during any one business day. But what if those multiple currency transactions occur on different business accounts at your credit union and those accounts share a common owner?
To aggregate or not to aggregate. Whether you aggregate these transactions or not will depend on your determination of whether the accounts are operating independently of each other.
****READ COMPLETE GUIDANCE; http://bit.ly/GCLmE6
Written by Bernadette Clair, Regulatory Compliance Counsel

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