Regulatory Alerts2001-08-23
Added
FinCEN Ruling 2001-2: Aggregation of Currency Transactions for CTR Filing
FinCEN determines that a bank must aggregate multiple currency transactions across separately incorporated businesses owned by the same individual when those entities are not operated separately and independently. This aggregation is required under 31 CFR § 103.22(c)(2) because common ownership combined with shared employees, cross-account funding, and unified signature authority indicates the transactions are conducted by or on behalf of one person. The ruling mandates that cash withdrawals totaling more than $10,000 in a single business day be treated as a single transaction for Currency Transaction Report purposes. FinCEN also reminds the bank of its continuing obligation to file suspicious activity reports under 31 CFR § 103.18 if transactions are suspected of circumventing reporting requirements.