Regulatory Alerts2012-03-16
Currency Transaction Report Aggregation for Businesses with Common Ownership
FinCEN issued this guidance to clarify how financial institutions must aggregate currency transactions conducted by businesses with common ownership under the Bank Secrecy Act. The document establishes that while separately incorporated entities are presumed independent, institutions must rebut this presumption by evaluating facts such as shared employees, locations, or commingled funds. If businesses are found to operate non-independently, their transactions must be aggregated for CTR filing purposes when total daily currency amounts exceed $10,000.
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