Regulatory Alerts2020-02-10
FinCEN Ruling on CTR Reporting for Sole Proprietorships and DBA Entities
The Financial Crimes Enforcement Network issued this administrative ruling to clarify Currency Transaction Report filing obligations for sole proprietorships and legal entities operating under a "doing business as" name. The guidance mandates that financial institutions report sole proprietorships by listing the individual owner's personal details in the primary section while using the DBA name as an alternate name. For legal entities, institutions must include headquarters data in the initial section and create separate sections for each involved location, ensuring accurate aggregation of cash transaction amounts.
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