CTRs: Aggregating Transactions for Entities with Common Ownership
Do institutions need to aggregate cash transactions for entities under common ownership? This is a question we get quite often and the answer is it depends. FinCEN address this in it’s “Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions” (FIN-2018-G001) back in 2018. FAQ #32 states:
With respect to legal entity customer that may share a common owner, unless there is an affirmative reason to believe otherwise, covered financial institutions should presume that different businesses that share a common owner are operating separately and independently from each other and from the common owner.
Thus, absent indications that the businesses are not operating independently (e.g. the businesses are staffed by the same employees and are located at the dame address, the accounts of one business are repeatedly used to pay the expenses of another business or of the common owner), financial institutions should not aggregate transactions involving those businesses with those of each other or with those of the common owner for CTR filing.
Kevin explains more in the video.
Published 2026/07/07
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).