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