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If a customer splits a deposit into a personal account and joint account, and the joint account deposit falls below the CTR reporting threshold, do both customers need to be listed as the transactor?

A bank's question concerns the completion of a Currency Transaction Report (CTR). In this scenario, Bob comes into the bank with $10,200 in cash. He deposits $10,100 into his sole-owner account and $100 into his joint account with his wife, Mary. When the bank files the CTR, Bob will be listed as the transactor, but does the bank need to list Mary on the CTR as benefitting from the transaction? She technically only received $100 of the total amount deposited, which is below the reporting threshold.

According to the Financial Crimes Enforcement Network (FinCEN), the answer is "Yes." A CTR is required due to the total amount of the cash deposited, and the bank must list both Bob and Mary on the CTR as befitting from the transaction. According to FinCEN, when a person conducts transactions in currency that exceed $10,000, all persons on whose behalf those transactions are conducted must appear on the CTR, even though one or more might not be connected to an amount exceeding $10,000. Thus, while Mary only received $100 of the total transaction, according to FinCEN Mary is involved in the overall transaction that requires reporting and must be listed in Part I as a person involved in the transaction. Accordingly, Mary would appear on the CTR, and in Item 21 for her portion of the transaction, the bank would enter $100 and the account number where the $100 was deposited.

Similarly, if Bob comes into the bank and deposits $6,000 cash into Joe's account and $7,000 cash into Sam's account, the bank would include Bob, Joe, and Sam on its CTR. Each is involved in the transactions that require reporting. (September 2018)

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